New US sanctions against Venezuelan government
On 5 August 2019, President Trump expanded the existing sanctions on Venezuela by issuing Executive Order "Blocking Property of the Government of Venezuela" (the "EO").
According to the EO, such further sanctions were necessary in light of "the continued usurpation of power by Nicolas Maduro" and the "human rights abuses, including arbitrary or unlawful arrest and detention of Venezuelan citizens, interference with freedom of expression … and ongoing attempts to undermine Interim President Juan Guaido".
At the outset, the EO freezes the property and assets of the "Government of Venezuela". Thus, US persons are generally prohibited from transacting with the "Government of Venezuela" unless specifically exempted. Further, all property and interests in property belonging to the "Government of Venezuela", and that come within US jurisdiction or within possession of a US person, must be blocked. Note that the EO defines the term "Government of Venezuela" rather widely to include, inter alia, any person who has acted directly or indirectly for or on behalf of e.g. any political instrumentality of the Venezuelan state or government.
Notably, the EO further authorizes imposition of asset freezing measures on "any person" determined to (i) have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person or entity whose property is blocked pursuant to the EO; or to be (ii) owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property is blocked pursuant to the EO. Thus, the EO can in principle apply also to non-US parties. At this point, the White House has according to Reuters declined to comment on such possible secondary sanctions effects.
Exemptions include transactions related to the provision of humanitarian articles such as food and medicine as well as the conduct of official business of the federal government.