Updated April 24, 2019
Venezuela: Overview of U.S. Sanctions
For more than a decade, the United States has employed
Silva (former defense minister and governor of Trujillo
sanctions as a policy tool in response to activities of the
State), and Ramón Rodríguez Chacín (former interior
Venezuelan government and Venezuelan individuals. These
minister and former governor of Guárico); in 2011, Freddy
have included sanctions related to terrorism, drug
Alirio Bernal Rosales and Amilicar Jesus Figueroa Salazar
trafficking, trafficking in persons, antidemocratic actions,
(United Socialist Party of Venezuela, or PSUV, politicians),
human rights violations, and corruption. Overall, the
Major General Cliver Antonio Alcalá Cordones, and
Treasury Department has imposed financial sanctions on
Ramon Isidro Madriz Moreno (a Venezuelan intelligence
111 individuals, and the State Department has revoked the
officer); in 2017, then-Vice President Tareck el Aissami;
visas of hundreds of individuals. On January 28, 2019, the
and in May 2018, Pedro Luis Martin (a former senior
Trump Administration announced sanctions on Venezuela’s
intelligence official) and two of his associates. Others
state-oil company, Petróleos de Venezuela, S.A., or
designated include drug trafficker Walid Makled, three dual
PdVSA. Several days before the imposition of the PdVSA
Lebanese-Venezuelan citizens allegedly involved in a drug
sanctions, the United States recognized Juan Guaidó, the
money-laundering network, and several Colombian drug
head of Venezuela’s National Assembly, as the country’s
traffickers with activity in Venezuela.
interim president and ceased to recognize Nicolás Maduro
Targeted Sanctions Related to Antidemocratic
as the president of Venezuela.
Actions, Human Rights Violations, and Corruption
Terrorism-Related Sanctions
In response to increasing repression in Venezuela, Congress
Since 2006, U.S. officials have expressed concerns about
enacted the Venezuela Defense of Human Rights and Civil
Venezuela’s lack of cooperation on antiterrorism efforts.
Society Act of 2014 (P.L. 113-278; 50 U.S.C. 1701 note) in
Since then, the Secretary of State has made an annual
December 2014. Among its provisions, the law requires the
determination that Venezuela is not “cooperating fully with
President to impose sanctions (asset blocking and visa
United States anti-terrorism efforts” pursuant to Section
restrictions) against those whom the President determines
40A of the Arms Export Control Act (22 U.S.C. 2781). The
are responsible for significant acts of violence or serious
most recent determination was made in May 2018. As a
human rights abuses associated with protests in February
result, the United States has prohibited all U.S. commercial
2014 or, more broadly, against anyone who has directed or
arms sales and retransfers to Venezuela since 2006.
ordered the arrest or prosecution of a person primarily
because of the person’s legitimate exercise of freedom of
In 2008, the Treasury Department imposed sanctions (asset
expression or assembly. In 2016, Congress extended the
freezing and prohibitions on transactions) on two
2014 act through 2019 in P.L. 114-194.
individuals and two travel agencies in Venezuela for
providing financial support to the radical Lebanon-based
In March 2015, President Obama issued E.O. 13692 to
Islamic Shiite group Hezbollah. The action was taken
implement P.L. 113-278, and the Treasury Department
pursuant to Executive Order (E.O.) 13224, aimed at
issued regulations in July 2015 (31 C.F.R. Part 591). The
impeding terrorist funding.
E.O. targets (for asset blocking and visa restrictions) those
Drug Trafficking-Related Sanctions
involved in actions or policies undermining democratic
processes or institutions; those involved in acts of violence
U.S. concerns about the lack of Venezuelan cooperation on
or conduct constituting a serious human rights abuse; those
counternarcotics efforts date back to 2005. Since then, the
taking actions that prohibit, limit, or penalize the exercise
President has made an annual determination, pursuant to
of freedom of expression or peaceful assembly; public
procedures set forth in the Foreign Relations Authorization
corruption by senior Venezuelan officials; and any person
Act, FY2003 (P.L. 107-228, §706; 22 U.S.C. 2291j), that
determined to be a current or former leader of any entity
Venezuela has failed demonstrably to adhere to its
engaged in any activity described above or a current or
obligations under international narcotics agreements.
former official of the government of Venezuela.
President Trump made the most recent determination for
FY2019 in September 2018, but also waived foreign aid
To date, the Treasury Department has imposed financial
restrictions for programs to support democracy promotion.
sanctions on 81 Venezuelans pursuant to E.O. 13692.
Under the Obama Administration, the Treasury Department
The Treasury Department has imposed economic sanctions
froze the assets of seven Venezuelans—six members of
on at least 22 individuals with connections to Venezuela
Venezuela’s security forces and a prosecutor involved in
and 27 companies by designating them as Specially
repressing antigovernment protesters. Under the Trump
Designated Narcotics Traffickers pursuant to the Foreign
Administration, as the political situation in Venezuela has
Narcotics Kingpin Designation Act (Kingpin Act; P.L. 106-
deteriorated, the Treasury Department sanctioned an
120, Title VIII; 21 U.S.C. 1901 et seq.).
additional 74 Venezuelan government and military officials
Designated individuals include several current or former
from May 2017 to April 2019. These officials include
Venezuelan officials: in 2008, General Hugo Carvajal
President Nicolás Maduro and his wife, Cecilia Flores;
(former military intelligence head), General Henry Rangel
Executive Vice President Delcy Rodriguez; PSUV First
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Venezuela: Overview of U.S. Sanctions
Vice President Diosdado Cabello; eight Supreme Court
Treasury sanctioned Venezuela’s Central Bank in order to
members; the leaders of Venezuela’s army, national guard,
cut off its access to U.S. currency and limit its ability to
and national police; four state governors; and the director of
conduct international financial transactions.
the Central Bank of Venezuela.
Additional Financial Sanctions
Broader Sanctions on the Oil and Gold Sectors
In addition to targeted sanctions against individuals and
On November 1, 2018, President Trump issued E.O. 13850,
companies, President Trump has imposed financial
setting forth a framework to block the assets of, and
sanctions on Venezuela through three additional E.O.s
prohibit certain transactions with, any person determined by
because of the government’s serious human rights abuses,
the Secretary of the Treasury, in consultation with the
antidemocratic actions, and responsibility for the deepening
Secretary of State, to operate in the gold sector (or any
humanitarian crisis. In August 2017, he issued E.O. 13808,
other sector of the economy as determined in the future by
which prohibits access to the U.S. financial markets by the
the Secretary of the Treasury) or to be responsible for or
Venezuelan government, including PdVSA, with certain
complicit in transactions involving deceptive practices or
exceptions to minimize the impact on the Venezuelan
corruption and the Venezuelan government. Currently, six
people and U.S. economic interests. The sanctions restrict
individuals are sanctioned pursuant to E.O. 13850: five
the Venezuelan government’s access to U.S. debt and
were sanctioned in January 2019 for involvement in a
equity markets.
corruption scheme involving Venezuela’s currency
exchange practices that generated more than $2.4 billion in
In March 2018, President Trump issued E.O. 13827 to
corrupt proceeds; the president of Venezuela’s state gold
prohibit transactions involving the Venezuelan
mining company was sanctioned in March 2019.
government’s issuance of digital currency, coin, or token.
The Maduro government launched a cryptocurrency known
On January 28, 2019, pursuant to E.O. 13850, the Treasury
as the petro in 2018 in an effort to circumvent sanctions.
Department designated PdVSA as operating in the oil sector
of the Venezuelan economy, and Secretary of the Treasury
In May 2018, President Trump issued E.O. 13835, which
Steven Mnuchin determined that the company was subject
prohibits transactions related to the purchase of Venezuelan
to U.S. sanctions. As a result, all property and interests in
debt, including accounts receivable, and to any debt owed
property of PdVSA subject to U.S. jurisdiction are blocked,
to Venezuela pledged as collateral. U.S. officials assert the
and U.S. persons generally are prohibited from engaging in
action was intended to deny corrupt Venezuelan officials
transactions with the company.
the ability to improperly value and sell off public assets in
return for kickbacks.
At the same time, OFAC issued general licenses to allow
Policy Considerations
certain transactions and activities related to PdVSA and its
Although Venezuelan oil exports to the United States
subsidiaries, some within specified time frames or wind-
already had been declining, sanctions on that trade are
down periods. Transactions with two U.S.-based PdVSA
requiring U.S. refineries that process Venezuelan crude oil
subsidiaries, PDV Holding, Inc. (PDVH) and CITGO
to find alternative sources. Some analysts are concerned
Holding, Inc., originally were authorized through July 27,
that the stronger sanctions on PdVSA are further
2019, but in March 2019, the Treasury Department
exacerbating Venezuela’s difficult humanitarian crisis,
extended a general license for 18 months. PDHV, CITGO,
already marked by shortages of food and medicines and
and other U.S. companies are authorized to import
mass migration, by limiting the country’s key source of
petroleum from PdVSA through April 28, 2019; payments
revenue. This is a particular concern in the event that
for these transactions benefiting PdVSA must be made into
Maduro remains in power over an extended period of time.
a blocked account in the United States. Several U.S.
Some observers also maintain that economic sanctions
companies with operations in Venezuela involving PdVSA
ultimately may need to be accompanied by efforts to foster
are authorized to continue their operations through July 27,
a negotiated solution leading to free and fair elections.
2019.
For guidance on the Venezuela sanctions, see U.S.
In March 2019, the Treasury Department expanded
Department of the Treasury, “Venezuela-Related
sanctions pursuant to EO 13850. On March 11, it
Sanctions,” at https://www.treasury.gov/resource-center/
sanctioned the Moscow-based Evrofinance Mosnarbank,
sanctions/programs/pages/venezuela.aspx; and U.S.
jointly owned by Russia and Venezuela, for helping PdVSA
Department of State, “Venezuela-Related Sanctions,” at
funnel its cash flow from oil sales. On March 19, it
https://www.state.gov/e/eb/tfs/spi/venezuela/.
sanctioned Venezuela’s state-owned gold sector company,
Minerven, for using illicit gold operations to help the
For more from CRS, see CRS In Focus IF10230,
regime financially. On March 22, it sanctioned the state-
Venezuela: Political Crisis and U.S. Policy; CRS Report
affiliated Venezuelan Economic and Social Development
R44841, Venezuela: Background and U.S. Relations; CRS
Bank (BANDES) and five of its subsidiaries that the
In Focus IF11029, The Venezuela Regional Migration
Maduro regime uses to move money outside of Venezuela.
Crisis; and CRS Insight IN11037, Venezuela Oil Sector
Sanctions: Market and Trade Impacts
.
In April 2019, the Treasury Department sanctioned 44
Mark P. Sullivan, Specialist in Latin American Affairs
vessels (along with 6 shipping companies) involved in
transporting Venezuelan oil, including 5 companies that
IF10715
have transported Venezuelan oil to Cuba. On April 17,

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Venezuela: Overview of U.S. Sanctions



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