Sanctions against Venezuela target actions of the government of President Nicolas Maduro restricting civil liberties and repressing popular protests. The US first imposed sanctions against the country in 2014, following government action against protestors. The EU and SECO imposed their own measures in 2017 following actions taken by the government during that year’s Constituent Assembly election. In 2019 the US extended the programme to target the Venezuelan government and state-owned entities to press for the removal of the Maduro government in favour of National Assembly leader Juan Guaido.
On 13th November 2023 the EU renewed its Venezuela sanctions by 6 months until 14th May 2024. The 6 month instead of 1 year extension took place in response to the “positive step towards the restoration of democracy”, following the signing of an electoral roadmap agreement between the opposition political alliance Venezuela’s Unitary Platform and representatives of President Nicolas Maduro.
On 10th November 2023 the EU deleted one entry – Tibisay Lucena Ramirez who died in April 2023 – and amended the statement of reasons for 16 entries, including government officials and military commanders, on its Venezuela sanctions list
Sanction Name
Restrictive Measures In View Of The Situation In Venezuela
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Travel Ban:
• A ban on the export of arms and equipment which might be used for internal repression, a ban on the export of surveillance equipment and the freezing of funds and a travel ban on those deemed to be responsible for serious human rights violations or abuses; the repression of civil society and democratic opposition; and those who undermine democracy or the rule of law in Venezuela, as well as their associates.
Exemptions
1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings.
Sanction Name
Ordinance on measures against Venezuela
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Travel Ban:
• A ban on the export of arms and equipment which might be used for internal repression, a ban on the export of surveillance equipment and the freezing of funds and a travel ban on those deemed to be responsible for serious human rights violations or abuses; the repression of civil society and democratic opposition; and those who undermine democracy or the rule of law in Venezuela, as well as their associates.
Exemptions
1. Asset freeze exemptions can be granted to prevent cases of rigor; in respect of existing contracts; to respect credits due under existing judicial, administrative or arbitral judgments; for diplomatic or consular missions; or to protect Swiss interests.
2. Travel ban exemptions may be granted on humanitarian grounds, to support the attendance of international conferences, to participate in political dialogue concerning Venezuela or if the protection of Swiss interests requires it.
On 16th January 2024 OFAC issued Venezuela-related General License 5N authorising certain transactions related to the Petróleos de Venezuela’s 2020 8.5% Bond on or after 16th April 2024.
On 29th January 2024 the US Department of State announced it was reviewing its decision to grant Venezuela certain relief from sanctions in response to the Venezuelan Supreme Court judgement upholding a ban which prevents opposition presidential candidate, Maria Corina Machado, from holding office. OFAC also issued Venezuela-related General License 43A authorising the wind down of transactions involving Venezuelan state-owned gold mining company CVG Compania General de Mineria de Venezuela CA.
On 2nd February 2024 OFAC published an update to FAQs related to the suspension of certain US sanctions with respect to Venezuela on 18th October 2023.
Sanction Name
Sanctions With Respect to the Situation in Venezuela
SANCTIONS
First Imposed
Last updated
Targets
Special Designation, Trade Restrictions and Travel Ban:
• Since February 2014 sanctions have been imposed on individuals found to be responsible for or complicit in human rights or political abuses during anti-government protests, or in public corruption by senior officials within the government of Venezuela. The programme also targets current and former leaders of such entities, as well as any entities which have directed or provided support to the activities mentioned above. Under these criteria, on 8th January 2019 OFAC sanctioned seven individuals and companies controlled by them, after they were allegedly involved in a corrupt scheme to take advantage of the Venezuelan Government’s currency exchange practices.
• In January 2018 the sanctions against Venezuela were expanded to include transactions related to digital currencies, coins or tokens issued by the Venezuelan Government, as well as dealings in Venezuelan state debt. In May 2018 sanctions were further expanded to include transactions related to the provision of financing and other dealings in debt owed to the Government of Venezuela or any debt owed to the Venezuelan Government pledged as collateral. In November 2018 sanctions were imposed on Venezuela’s gold sector.
• After Juan Guaido, with backing from the US government, declared himself acting President of Venezuela on 23rd January 2019, OFAC significantly increased the intensity of its sanctions programme to facilitate the removal of President Maduro’s government. To this end, on 25th January 2019, sanctions were imposed on state oil company PDVSA and the Central Bank of Venezuela. Government officials and politicians aligned with Maduro have since been sanctioned, while in March 2019 sanctions were imposed on state-owned ferrous metals mining company CVG Compania General de Mineria de Venezuela CA (“Minerven”) and Venezuelan development bank Banco de Desarrollo Economico y Social de Venezuela (“BANDES”) and four of its subsidiaries.
Exemptions
1. In 2019 a number of general licences were issued to limit the impact of sanctions against Venezuela for US persons and companies. Certain transactions involving three Venezuelan state-owned entities which have a significant presence in the US – CITGO Holding Inc, PDV Holding Inc, Nynas AB and any of their subsidiaries – are authorised.
2. In addition, five entities which have significant existing commercial agreements and contracts with PDVSA – Chevron Corporation, Halliburton, Schlumberger Ltd, Baker Hughes and Weatherford International and their subsidiaries – were authorised to engage in certain transactions with PDVSA until 1st December 2022. US persons in Venezuela are also allowed to purchase refined petroleum products from PDVSA.
3. Similarly, five entities – MasterCard Incorporated, Visa Inc, American Express Company, Western Union Company, MoneyGram International – along with US persons maintaining, operating or closing accounts with BANDES and its four subsidiaries were authorised to complete such transactions.
4. There are also exemptions to protect US and non-US customers with exposure to the Venezuelan banking sector. Transactions related to the provision of financing for and other dealings in certain bonds of the Venezuela Government and PDVSA are authorised as long as they are conducted by a non-US person.
5. Transactions related to US Government official business are also authorised.
6. Transactions with the following Venezuelan government employees are authorised: those who are US citizens, permanent resident aliens, those with valid immigrant or non-immigrant visas or former Venezuelan government employees.
7. In July 2021 OFAC issued General License 5G, authorising US entities to acquire bonds issued by Petroleos de Venezuela. General Licence 5I has now extended the exemption until 20th January 2023.
8. On 20th January 2022 OFAC issued General License 5I, “Authorizing Certain Transactions Related to the Petroleos de Venezuela SA 2020 8.5 Percent Bond”.
9. On 27th May 2022 OFAC issued the Venezuela-related General License 8J, authorising transactions involving Petroleas de Venezuela SA necessary for the limited maintenance of essential operations in Venezuela or the Wind Down of Operations in Venezuela for certain entities.
10. On 7th July 2022 OFAC issued Venezuela-related General License 40A, which authorises certain transactions involving the exportation and reexportation of liquefied petroleum gas to Venezuela.
11. On 26th November 2022 OFAC issued Venezuela-related General License 8K, authorising transactions involving Petroleos de Venezuela SA, necessary for the maintenance of essential operations in Venezuela or the winding down of operations in Venezuela for certain entities. On the same day, OFAC also issued General License 41 authorising certain transactions related to Chevron Corporation’s joint ventures in Venezuela.
12. General License 31B authorises certain transactions involving the IV Venezuelan National Assembly and certain other persons.
13. General License 8L authorises transactions involving Petroleos de Venezuela SA necessary for the limited maintenance of essential operations in Venezuela or the wind down of operations in Venezuela for certain entities. General License 5L authorises certain transactions related to the Petroleos de Venezuela SA 2020 8.5% bond on or after 20th October 2023.
14. General License 42 authorises certain transactions related to the negotiation of certain settlement agreements with the IV Venezuelan National Assembly and Certain Other Persons
15. General License 39B authorises certain activities to respond to Covid-19.
16. General License 40B authorises certain transactions involving the exportation or reexportation of liquefied petroleum gas to Venezuela.
17. General License 5L authorises certain transactions related to the Petroleas de Venezuela SA’s 2020 8.5% bond on or after 20th October 2023.
Links 1
Sanction Name
Venezuela (Sanctions) (EU Exit) Regulations 2019
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Travel Ban:
• A ban on the export of arms and equipment which might be used for internal repression, a ban on the export of surveillance equipment and the freezing of funds and a travel ban on those deemed to be responsible for serious human rights violations or abuses; the repression of civil society and democratic opposition; and those who undermine democracy or the rule of law in Venezuela, as well as their associates.
Exemptions
1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings.
