pi_circular Geopolitical riskCompliance & regulation West of England
Sanctions 16 Aug, 2017 Venezuela - US Sanctions The Club has received a number of recent enquiries regarding sanctions against Venezuela, especially in light of President Trump’s decision to impose personal sanctions on President Maduro. We therefore take this opportunity to set out the current US sanctions regime against Venezuela (there are currently no equivalent sanctions imposed by the EU), based on advice from the Club’s US attorneys Freehill Hogan & Mahar. There are no cargo-specific sanctions. However, Executive Order 13692 of March 8, 2015 (“the E.O.”) cited the Venezuelan government for a variety of abuses and ordered the blocking of any assets in the US, or in the control of US persons, of persons complicit in the abuses complained of, and of the persons named in the Annex to the order or subsequently designated by the Secretary of the Treasury. A copy of the E.O. can be found here Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela . The E.O. also calls for a blocking of the assets of any person (not just a US person) who has “…materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of…” any person whose property is blocked under the E.O. More recently OFAC added thirteen people to the Venezuelan SDN list pursuant to the E.O., details of whom can be found here Treasury Sanctions 13 Current and Former Senior Officials of the Government of Venezuela . This brings the list to 37 people (click Sanctions List Search for a full name listing) and further details of each are available by using OFAC’s useful SDN checking tool . Members should ensure that when fixing business for Venezuela they do not to enter into transactions which involve any of the persons named in the SDN list, acting either in a personal capacity or as an officer of a company. The list now includes Simon Alejando Zerpa Delgardo who is listed as b
Venezuela - US Sanctions
West of England
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