On June 18, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the addition of three individuals and eight entities to its list of Specially Designated Nationals and Blocked Persons (SDN List), pursuant to Executive Order 13850, for “their activities in or associated with a network attempting to evade United States sanctions on Venezuela’s oil sector.” OFAC also identified two vessels as blocked property belonging to the designated persons and issued a general license authorizing wind-down activities with certain of the designated persons, as well as an FAQ regarding the general license. Finally, OFAC announced the delisting of two entities previously included on the SDN List for operating in the oil sector of the Venezuelan economy.
The actions are the latest in a string of recent designations targeting entities involved in the Venezuelan oil sector, which has been a particular focus for OFAC of late. The latest actions offer a number of insights for companies doing business with Venezuela and operating in the oil and shipping industries more broadly. We highlight three key takeaways below.