Development in US sanctions relating to Venezuela

On 17 April 2019, OFAC designated Banco Central de Venezuela under Executive Order 13850, as amended, for operating within the Venezuelan economy. At the outset, this means that all dealings involving Banco Central de Venezuela, or entities owned 50 % or more by this bank, are prohibited if subject to US jurisdiction.

However, concurrent with the designation, OFAC also issued two new General Licences (GL 19 and GL 20) and further amended five General Licences (now GLs 4B, 15A, 16A and 9D). With that, certain transactions involving Banco Central de Venezuela that would otherwise be prohibited, are generally authorized. According to the US Department of the Treasury, these authorizations aim to "ensure that regular debit and credit card transactions can proceed and personal remittances and humanitarian assistance continue unabated and are able to reach those suffering under the Maduro regime’s repression".

For further details on the abovementioned OFAC actions, see OFAC Notice and OFAC FAQ 665.

For background information on the US sanctions against Venezuela and of the function of General Licences, see our previous Sanctions Alerts of 12 March 2019 and of 15 March 2019. See also our Sanctions Alert of 3 April 2019 about the possibility of future US secondary sanctions relating to Venezuela.