Updated February 21, 2020
Venezuela: Overview of U.S. Sanctions
For more than a decade, the United States has imposed
Narcotics Traffickers pursuant to the Foreign Narcotics
sanctions in response to activities of the Venezuelan
Kingpin Designation Act (P.L. 106-120, Title VIII; 21
government and Venezuelan individuals. In response to the
U.S.C. 1901 et seq.). Designated individuals include current
authoritarian leadership of Nicolás Maduro, the Trump
and former Venezuelan officials, such as then-Vice
Administration has significantly expanded sanctions. As of
President Tareck el Aissami (2017) and Pedro Luis Martin
January 22, 2020, the Treasury Department has imposed
(a former senior intelligence official) and two associates
sanctions on at least 144 Venezuelan or Venezuelan-
(2018). Others include drug trafficker Walid Makled, three
connected individuals, and the State Department has
dual Lebanese-Venezuelan citizens allegedly involved in a
revoked the visas of hundreds of individuals and their
drug money-laundering network, and several Colombian
families. The Trump Administration also has imposed
drug traffickers with activity in Venezuela.
sanctions on Venezuela’s state oil company (Petróleos de
Venezuela, S.A., or PdVSA), government, and central bank.
Targeted Sanctions Related to Antidemocratic
Actions, Human Rights Violations, and Corruption
Sanctions have increased economic pressure on the Maduro
In response to increasing repression in Venezuela, Congress
government, accelerating a decline in oil production.
enacted the Venezuela Defense of Human Rights and Civil
Nevertheless, Maduro remains in power a year since the
Society Act of 2014 (P.L. 113-278; 50 U.S.C. 1701 note) in
United States ceased to recognize him as president. The
2014. Among its provisions, the law requires the President
Trump Administration has promised continued support to
to impose sanctions (asset blocking and visa restrictions)
National Assembly President Juan Guaidó, whom the
against those whom the President identifies as responsible
United States and 57 governments recognize as interim
for significant acts of violence or serious human rights
president of Venezuela. Recent U.S. sanctions targeted
abuses or anyone who has ordered the arrest or prosecution
legislators who tried to block Guaidó’s January 2020
of a person because of the person’s legitimate exercise of
reelection as National Assembly president. On February 18,
freedom of expression or assembly. In 2016, Congress
2020, Treasury sanctioned Rosneft Trading S.A., a
extended this act through 2019 in P.L. 114-194.
subsidiary of the Russian state-controlled Rosneft Oil
Company, for facilitating Venezuelan oil exports.
In March 2015, President Obama issued E.O. 13692 to
implement P.L. 113-278, and Treasury issued regulations in
Terrorism-Related Sanctions
July 2015 (31 C.F.R. Part 591). The E.O. targets (for asset
Since 2006, the Secretary of State has made an annual
blocking and visa restrictions) those involved in actions or
determination that Venezuela is not “cooperating fully with
policies undermining democratic processes or institutions;
United States anti-terrorism efforts” pursuant to Section
serious human rights abuses; prohibiting, limiting, or
40A of the Arms Export Control Act (22 U.S.C. 2781). The
penalizing freedom of expression or peaceful assembly; and
most recent determination was made in May 2019. As a
public corruption. It includes any person who is a current or
result, the United States has prohibited all U.S. commercial
former leader of any entity engaged in any of those
arms sales and retransfers to Venezuela since 2006.
activities, as well as current or former government officials.
In 2008, Treasury imposed financial sanctions on two
As of January 22, 2020, Treasury has financial sanctions on
individuals and two travel agencies in Venezuela for
98 Venezuelans pursuant to E.O. 13692. Under the Obama
providing financial support to the radical Lebanon-based
Administration, Treasury froze the assets of seven
Islamic Shiite group Hezbollah. Pursuant to Executive
Venezuelans—six members of Venezuela’s security forces
Order (E.O.) 13224, this related to terrorist funding.
and a prosecutor who repressed protesters. Under the
Trump Administration, Treasury currently has sanctions on
Drug Trafficking-Related Sanctions
an additional 91 Venezuelan officials, including President
Since 2005, pursuant to procedures in the Foreign Relations
Maduro; his wife, Cecilia Flores, and son, Nicolás Maduro
Authorization Act, FY2003 (P.L. 107-228, §706; 22 U.S.C.
Guerra; Executive Vice President Delcy Rodriguez;
2291j), the President has made an annual determination that
Diosdado Cabello (Socialist party president); eight supreme
Venezuela has failed demonstrably to adhere to its
court judges; the leaders of Venezuela’s army, national
obligations under international narcotics agreements.
guard, and national police; four state governors; the director
President Trump made the most recent determination for
of the central bank; and the foreign minister. On May 7,
FY2020 in August 2019 but waived foreign aid restrictions
2019, Treasury lifted sanctions against the former head of
for programs that support the interim government.
Venezuela’s intelligence service, General Manuel
Cristopher Figuera, who broke ranks with Maduro.
Treasury has imposed economic sanctions on at least 22
individuals with connections to Venezuela and 27
companies by designating them as Specially Designated
https://crsreports.congress.gov

Venezuela: Overview of U.S. Sanctions
Additional Financial Sanctions
central bank; in July, it sanctioned Venezuela’s military
President Trump has imposed financial sanctions on
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.
President Trump issued E.O. 13827 to prohibit transactions
involving the Venezuelan government’s issuance of digital
Sanctions on the Maduro Government and Persons
currency, coin, or token. In May 2018, President Trump
Transacting with or Assisting That Government
issued E.O. 13835, which prohibits transactions related to
On August 5, 2019, President Trump issued E.O. 13884,
purchasing Venezuelan debt, including accounts receivable,
blocking (freezing) the property and interests of the Maduro
and any debt owed to Venezuela pledged as collateral.
government in the United States and within the control of
U.S. persons. The order prohibits U.S. persons from
Broader Sectoral Sanctions
engaging in transactions with the Maduro government
On November 1, 2018, President Trump issued E.O. 13850.
unless authorized by OFAC. E.O. 13884 also authorized
This E.O. set forth a framework to block the assets of, and
financial sanctions and visa restrictions on non-U.S.
prohibit certain transactions with, any person determined by
persons that assist or support the Maduro government,
the Secretary of the Treasury to operate in sectors of the
which could lead to U.S. sanctions on foreign energy
economy or to engage in corrupt transactions with the
companies working with PdVSA. To allow humanitarian
Maduro government. Some 19 individuals are sanctioned
assistance to the Venezuelan people, OFAC issued licenses
pursuant to E.O. 13850. They include 5 people and 23
authorizing transactions involving the delivery of food,
entities for involvement in a $2.4 billion currency exchange
agricultural commodities, and medicine; remittances;
corruption scheme; the president of the state gold mining
international organizations; and communications services.
company; and at least 13 individuals and 19 entities for
siphoning millions of dollars from Venezuela’s emergency
On February 18, 2020, Treasury imposed sanctions on
food distribution system.
Rosneft Trading S.A., a Geneva-based subsidiary of
Russia’s Rosneft oil company, and its owner for helping the
On January 28, 2019, pursuant to E.O. 13850, Treasury
Maduro government skirt U.S. oil sanctions. Rosneft
designated PdVSA as operating in the oil sector of the
Trading has handled some 70% of PdVSA’s recent oil
Venezuelan economy, and Secretary of the Treasury Steven
shipments, according to U.S. officials. This move has
Mnuchin determined that the company was subject to U.S.
ratcheted up U.S. tensions with Russia over Venezuela; it
sanctions. As a result, all property and interests in property
could portend future secondary sanctions on other energy
of PdVSA subject to U.S. jurisdiction are blocked, and U.S.
companies.
persons (companies or individuals) generally are prohibited
from engaging in transactions with the company.
Policy Considerations
There has been bipartisan support in Congress for targeted
At the same time, Treasury’s Office of Foreign Assets
sanctions against Maduro officials, but opinions on broader
Control (OFAC) issued general licenses to allow certain
sanctions vary. Some support U.S. economic sanctions as a
transactions and activities related to PdVSA and its
way to pressure the Maduro government. Others are
subsidiaries, some for specified wind-down periods. OFAC
concerned about the humanitarian effects of those
first authorized transactions with U.S.-based PdVSA
sanctions, particularly because Maduro is still in power.
subsidiaries, PDV Holding, Inc. (PDVH) and CITGO
Holding, Inc. through July 27, 2019. In March 2019, the
The 116th Congress has enacted legislation and conducted
general license for those entities was extended for 18
oversight regarding U.S. sanctions on Venezuela. Enacted
months. OFAC authorized PDVH, CITGO, and other U.S.
in December 2019, P.L. 116-94 codifies sanctions regarding
companies to import petroleum from PdVSA through April
corruption and undemocratic actions and those prohibiting
28, 2019, but payments had to be made to a blocked U.S.
the Maduro government’s ability to trade gold, finance
account. OFAC initially authorized several U.S. companies
debt, or use cryptocurrencies to avoid U.S. sanctions. S.
with operations in Venezuela involving PdVSA (including
2977, introduced in December 2019, would extend the
Chevron) to continue operating through July 27, 2019; that
targeted sanctions set forth in P.L. 113-278 through 2021.
authorization now extends through April 22, 2020.
See U.S. Department of the Treasury, “Venezuela-Related
In March 2019, Treasury sanctioned the Moscow-based
Sanctions,” at https://www.treasury.gov/resource-center/
Evrofinance Mosnarbank (owned by Russia and Venezuela)
sanctions/programs/pages/venezuela.aspx; and U.S.
for helping PdVSA funnel revenue from oil sales. Treasury
Department of State, “Venezuela-Related Sanctions,” at
then sanctioned Venezuela’s state-owned gold sector
https://www.state.gov/venezuela-related-sanctions/.
company, Minerven, for using illicit gold operations to
support Maduro. It also sanctioned the state-affiliated
Also see CRS In Focus IF10230, Venezuela: Political
Venezuelan Economic and Social Development Bank and
Crisis and U.S. Policy; and CRS Report R44841,
subsidiaries that the Maduro government uses to move
Venezuela: Background and U.S. Relations.
money abroad. In April, Treasury sanctioned Venezuela’s
https://crsreports.congress.gov

Venezuela: Overview of U.S. Sanctions

Clare Ribando Seelke, Specialist in Latin American
Affairs
IF10715


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