Updated January 22, 2020
Venezuela: Overview of U.S. Sanctions
For more than a decade, the United States has imposed
Kingpin Designation Act (P.L. 106-120, Title VIII; 21
sanctions in response to activities of the Venezuelan
U.S.C. 1901 et seq.).
government and Venezuelan individuals. In response to the
authoritarian leadership of Nicolás Maduro, the Trump
Designated individuals include several current or former
Administration has significantly expanded sanctions. As of
Venezuelan officials. Some of the more recent sanctions
January 22, 2020, the Treasury Department has imposed
include then-Vice President Tareck el Aissami in 2017 and
sanctions on at least 144 Venezuelan or Venezuelan-
Pedro Luis Martin (a former senior intelligence official) and
connected individuals, and the State Department has
two associates in May 2018. Others designated include drug
revoked the visas of hundreds of individuals and their
trafficker Walid Makled, three dual Lebanese-Venezuelan
families. The Trump Administration also has imposed
citizens allegedly involved in a drug money laundering
sanctions on Venezuela’s state oil company (Petróleos de
network, and several Colombian drug traffickers with
Venezuela, S.A., or PdVSA), government, and central bank.
activity in Venezuela.
Sanctions have increased economic pressure on the Maduro
Targeted Sanctions Related to Antidemocratic
government, accelerating a decline in oil production.
Actions, Human Rights Violations, and Corruption
Nevertheless, Maduro remains in power a year since the
In response to increasing repression in Venezuela, Congress
United States ceased to recognize him as president. The
enacted the Venezuela Defense of Human Rights and Civil
Trump Administration has promised continued support to
Society Act of 2014 (P.L. 113-278; 50 U.S.C. 1701 note) in
National Assembly President Juan Guaidó, whom the
2014. Among its provisions, the law requires the President
United States and 57 governments recognize as interim
to impose sanctions (asset blocking and visa restrictions)
president of Venezuela. Recent U.S. sanctions targeted
against those whom the President identifies as responsible
legislators who tried to block Guaidó’s January 2020 re-
for significant acts of violence or serious human rights
election as National Assembly president.
abuses or anyone who has ordered the arrest or prosecution
of a person because of the person’s legitimate exercise of
Terrorism-Related Sanctions
freedom of expression or assembly. In 2016, Congress
Since 2006, the Secretary of State has made an annual
extended this act through 2019 in P.L. 114-194.
determination that Venezuela is not “cooperating fully with
United States anti-terrorism efforts” pursuant to Section
In March 2015, President Obama issued E.O. 13692 to
40A of the Arms Export Control Act (22 U.S.C. 2781). The
implement P.L. 113-278, and Treasury issued regulations in
most recent determination was made in May 2019. As a
July 2015 (31 C.F.R. Part 591). The E.O. targets (for asset
result, the United States has prohibited all U.S. commercial
blocking and visa restrictions) those involved in actions or
arms sales and retransfers to Venezuela since 2006.
policies undermining democratic processes or institutions;
those involved in acts of violence or conduct constituting a
In 2008, Treasury imposed financial sanctions on two
serious human rights abuse; those taking actions that
individuals and two travel agencies in Venezuela for
prohibit, limit, or penalize the exercise of freedom of
providing financial support to the radical Lebanon-based
expression or peaceful assembly; public corruption by
Islamic Shiite group Hezbollah. Pursuant to Executive
senior Venezuelan officials; and any person determined to
Order (E.O.) 13224, the action aimed at impeding terrorist
be a current or former leader of any entity engaged in any
funding.
activity described above or a current or former official of
the government of Venezuela.
Drug Trafficking-Related Sanctions
Since 2005, pursuant to procedures in the Foreign Relations
As of January 22, 2020, Treasury has financial sanctions on
Authorization Act, FY2003 (P.L. 107-228, §706; 22 U.S.C.
98 Venezuelans pursuant to E.O. 13692. Under the Obama
2291j), the President has made an annual determination that
Administration, Treasury froze the assets of seven
Venezuela has failed demonstrably to adhere to its
Venezuelans—six members of Venezuela’s security forces
obligations under international narcotics agreements.
and a prosecutor who repressed protesters. Under the
President Trump made the most recent determination for
Trump Administration, Treasury currently has sanctions on
FY2020 in August 2019 but waived foreign aid restrictions
an additional 91 Venezuelan officials, including President
for programs that support the interim government.
Maduro; his wife, Cecilia Flores, and son, Nicolás Maduro
Guerra; Executive Vice President Delcy Rodriguez;
Treasury has imposed economic sanctions on at least 22
Diosdado Cabello (Socialist party president); eight supreme
individuals with connections to Venezuela and 27
court judges; the leaders of Venezuela’s army, national
companies by designating them as Specially Designated
guard, and national police; four state governors; the director
Narcotics Traffickers pursuant to the Foreign Narcotics
of the central bank; and the foreign minister. On May 7,
2019, Treasury lifted sanctions against the former head of
https://crsreports.congress.gov

Venezuela: Overview of U.S. Sanctions
Venezuela’s intelligence service, General Manuel
affiliated Venezuelan Economic and Social Development
Cristopher Figuera, who broke ranks with Maduro.
Bank and subsidiaries that the Maduro government uses to
move money abroad. In April, Treasury sanctioned
Additional Financial Sanctions
Venezuela’s central bank; in July, it sanctioned Venezuela’s
President Trump has imposed financial sanctions on
military counterintelligence agency.
Venezuela through E.O.s because of the government’s
human rights abuses and antidemocratic actions. In August
In April and in September 2019, Treasury sanctioned
2017, he issued E.O. 13808, which prohibits access to U.S.
companies and vessels involved in transporting Venezuelan
financial markets by the Venezuelan government, including
oil to Cuba. Companies that have stopped those shipments
PdVSA, with certain exceptions to minimize the impact on
have been delisted. On July 3, Treasury designated Cuba’s
the Venezuelan people and U.S. interests. In March 2018,
state oil import and export company, due to Cuba’s
President Trump issued E.O. 13827 to prohibit transactions
continued support for the Maduro government.
involving the Venezuelan government’s issuance of digital
currency, coin, or token. In May 2018, President Trump
Sanctions on the Maduro Government and Persons
issued E.O. 13835, which prohibits transactions related to
Transacting with or Assisting That Government
purchasing Venezuelan debt, including accounts receivable,
On August 5, 2019, President Trump issued E.O. 13884,
and any debt owed to Venezuela pledged as collateral.
blocking (freezing) the property and interests of the Maduro
government in the United States and within the control of
Broader Sectoral Sanctions
U.S. persons. The order prohibits U.S. persons from
On November 1, 2018, President Trump issued E.O. 13850.
engaging in transactions with the Maduro government
This E.O. set forth a framework to block the assets of, and
unless authorized by OFAC. E.O. 13884 also authorized
prohibit certain transactions with, any person determined by
financial sanctions and visa restrictions on non-U.S.
the Secretary of the Treasury to operate in sectors of the
persons that assist or support the Maduro government,
economy or to engage in corrupt transactions with the
which could lead to U.S. sanctions on foreign energy
Maduro government. Some 19 individuals are sanctioned
companies working with PdVSA. To allow humanitarian
pursuant to E.O. 13850. They include 5 people and 23
assistance to the Venezuelan people, OFAC issued licenses
entities for involvement in a $2.4 billion currency exchange
authorizing transactions involving the delivery of food,
corruption scheme; the president of the state gold mining
agricultural commodities, and medicine; remittances;
company; and at least 13 individuals and 19 entities for
international organizations; and communications services.
siphoning millions of dollars from Venezuela’s emergency
Five people have since been sanctioned under E.O. 13884.
food distribution system.
Policy Considerations
On January 28, 2019, pursuant to E.O. 13850, Treasury
There has been bipartisan support in Congress for targeted
designated PdVSA as operating in the oil sector of the
sanctions against Maduro officials, but opinions on broader
Venezuelan economy, and Secretary of the Treasury Steven
sanctions vary. Some support U.S. economic sanctions as a
Mnuchin determined that the company was subject to U.S.
way to maintain pressure on the Maduro government.
sanctions. As a result, all property and interests in property
Others are concerned about the humanitarian effects of
of PdVSA subject to U.S. jurisdiction are blocked, and U.S.
those sanctions, particularly since they have thus far been
persons (companies or individuals) generally are prohibited
unable to dislodge Maduro from power.
from engaging in transactions with the company.
The 116th Congress has enacted legislation and conducted
At the same time, Treasury’s Office of Foreign Assets
oversight regarding U.S. sanctions on Venezuela. In May
Control (OFAC) issued general licenses to allow certain
2019, the Senate Foreign Relations Committee ordered S.
transactions and activities related to PdVSA and its
1025 reported with an amendment; S. 1025 was then
subsidiaries, some for specified wind-down periods. OFAC
incorporated into P.L. 116-94. Enacted in December 2019,
first authorized transactions with U.S.-based PdVSA
P.L. 116-94 codifies sanctions regarding corruption and
subsidiaries, PDV Holding, Inc. (PDVH) and CITGO
undemocratic actions, as well as those prohibiting the
Holding, Inc. through July 27, 2019. In March 2019, the
Maduro government’s ability to trade gold, finance debt, or
general license for those entities was extended for 18
use cryptocurrencies to avoid U.S. sanctions. S. 2977,
months. OFAC authorized PDVH, CITGO, and other U.S.
introduced in December 2019, would extend the targeted
companies to import petroleum from PdVSA through April
sanctions established in P.L. 113-278 through 2021.
28, 2019, but payments had to be made to a blocked U.S.
account. OFAC initially authorized several U.S. companies
See U.S. Department of the Treasury, “Venezuela-Related
with operations in Venezuela involving PdVSA (including
Sanctions,” at https://www.treasury.gov/resource-center/
Chevron) to continue operating through July 27, 2019; that
sanctions/programs/pages/venezuela.aspx; and U.S.
authorization now extends through April 22, 2020.
Department of State, “Venezuela-Related Sanctions,” at
https://www.state.gov/venezuela-related-sanctions/.
In March 2019, Treasury sanctioned the Moscow-based
Evrofinance Mosnarbank, (owned by Russia and
Also see CRS In Focus IF10230, Venezuela: Political
Venezuela) for helping PdVSA funnel revenue from oil
Crisis and U.S. Policy; and CRS Report R44841,
sales. Treasury then sanctioned Venezuela’s state-owned
Venezuela: Background and U.S. Relations.
gold sector company, Minerven, for using illicit gold
operations to support Maduro. It also sanctioned the state-
https://crsreports.congress.gov

Venezuela: Overview of U.S. Sanctions

Clare Ribando Seelke, Specialist in Latin American
Affairs
IF10715


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