On August 5, President Trump signed an Executive Order (EO) blocking, among other things, all property and interests in property of the Government of Venezuela and any entity majority-owned, controlled by, or acting on behalf of the Venezuelan government. In connection with this EO, OFAC published new FAQs, as well as 13 new and 12 amended general licenses. The general licenses include an amended General License 7C, which allows for certain transactions involving CITGO and PDV Holding, Inc., and a new General License 28, which authorizes certain activities necessary for the wind down of operations or existing contracts with entities blocked under the EO, to be concluded prior to September 4, 2019.
It is important to note that this new EO provides broad latitude for the U.S. government to impose sanctions on non-Venezuelan entities doing business in Venezuela. Although it is not yet known how the U.S. government will use this new authority, it is possible that the EO will have a broader regional impact, particularly on countries such as Colombia who have historic ties to Venezuela. As such, for the time being, U.S. companies should tread carefully with any entities that are known to have significant dealings with Venezuela and Venezuelan government-owned entities.
For more information on how this could impact your business, contact: