New Sanctions Related to the Financial Sector of the Venezuelan Economy
On April 17, 2019, the Office of Foreign Assets Control (“OFAC”) added Banco Central de Venezuela to its list of Specially Designated Nationals and Blocked Persons (SDN List) pursuant to Executive Order 13850 issued on November 1, 2018 by President Donald J. Trump, for “operating in the financial sector of the Venezuelan economy.” Accordingly, all property or interest in property of this financial institution within or transiting U.S. jurisdiction has been blocked. Additionally, if they are not authorized by a general or specific license issued by OFAC, U.S. persons are prohibited from engaging in transactions with this financial institution or with entities in which they have, directly or indirectly, 50% or greater ownership interest.
On the same date, OFAC amended the following general licenses: i) “3D Authorizing Transactions Related to, Provision of Financing for, and Other Dealings in Certain Bonds”; ii) “4A Authorizing New Debt Transactions and Transactions involving Certain Banks Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices or Replacement Parts and Components”; iii) “9C Authorizing Transactions Related to Dealings in Certain Securities”; iv) “15 Authorizing Transactions Involving Certain Banks Prohibited by Executive Order 13850 for Certain Entities”; v) “16 Authorizing Maintenance of U.S. Person Accounts and Noncommercial, Personal Remittances involving Certain Banks.”
Additionally, OFAC issued two new general licenses: “19 Authorizing Certain Activities Necessary to the Wind Down of Operations or Existing Contracts Involving Central Bank of Venezuela”; and “20 Authorizing Official Activities of Certain International Organizations Involving Central Bank of Venezuela.”