Venezuela: Overview of U.S. Sanctions



Updated August 20, 2020
Venezuela: Overview of U.S. Sanctions
For more than a decade, the United States has imposed
U.S.C. 1901 et seq.). Designated individuals include current
sanctions in response to activities of the Venezuelan
and former Venezuelan officials, such as then-Vice
government and Venezuelan individuals. In response to the
President Tareck el Aissami (2017) and Pedro Luis Martin
authoritarian leadership of Nicolás Maduro, the Trump
(a former senior intelligence official) and two associates
Administration has significantly expanded sanctions. As of
(2018). Others include drug trafficker Walid Makled, three
August 20, 2020, the Treasury Department has imposed
dual Lebanese-Venezuelan citizens allegedly involved in a
sanctions on more than 150 Venezuelan or Venezuelan-
drug money-laundering network, and several Colombian
connected individuals, and the State Department has
drug traffickers with activity in Venezuela.
revoked the visas of more than 1,000 individuals and their
families. The Trump Administration also has imposed
Targeted Sanctions Related to Antidemocratic
sanctions on Venezuela’s state oil company (Petróleos de
Actions, Human Rights Violations, and Corruption
Venezuela, S.A., or PdVSA), government, and central bank.
In response to increasing repression in Venezuela, Congress
enacted the Venezuela Defense of Human Rights and Civil
Sanctions have increased economic pressure on the Maduro
Society Act of 2014 (P.L. 113-278; 50 U.S.C. 1701 note) in
government, accelerating a decline in oil production.
2014. Among its provisions, the law requires the President
Nevertheless, Maduro remains in power a year and a half
to impose sanctions (asset blocking and visa restrictions)
since the United States ceased to recognize his presidency.
against those whom the President identifies as responsible
The Trump Administration has promised continued support
for significant acts of violence or serious human rights
to National Assembly President Juan Guaidó, whom the
abuses or anyone who has ordered the arrest or prosecution
United States and 57 governments recognize as interim
of a person because of the person’s legitimate exercise of
president of Venezuela. In 2020, Treasury has sanctioned
freedom of expression or assembly. Congress extended this
two subsidiaries of the Russian state-controlled Rosneft Oil
act through 2019 in P.L. 114-194. In December 2019,
Company for facilitating Venezuelan oil exports and four
Congress extended this act through 2023 in P.L. 116-94.
shipping companies for transporting Venezuelan oil.
In March 2015, President Obama issued E.O. 13692 to
Terrorism-Related Sanctions
implement P.L. 113-278, and Treasury issued regulations in
Since 2006, the Secretary of State has made an annual
July 2015 (31 C.F.R. Part 591). The E.O. targets (for asset
determination that Venezuela is not “cooperating fully with
blocking and visa restrictions) those involved in actions or
United States anti-terrorism efforts” pursuant to Section
policies undermining democratic processes or institutions;
40A of the Arms Export Control Act (22 U.S.C. 2781). The
serious human rights abuses; prohibiting, limiting, or
most recent determination was made in May 2020. As a
penalizing freedom of expression or peaceful assembly; and
result, the United States has prohibited all U.S. commercial
public corruption. It includes any person who is a current or
arms sales and retransfers to Venezuela since 2006.
former leader of any entity engaged in any of those
activities, as well as current or former government officials .
In 2008, Treasury imposed financial sanctions on two
individuals and two travel agencies in Venezuela for
As of August 20, 2020, Treasury has imposed financial
financially supporting the radical Lebanon-based Islamic
sanctions on 100 Venezuelans pursuant to E.O. 13692.
Shiite group Hezbollah. Pursuant to Executive Order (E.O.)
Under the Obama Administration, Treasury froze the assets
13224, those sanctions related to terrorist funding.
of seven Venezuelans—six members of Venezuela’s
security forces and a prosecutor who repressed protesters.
Drug Trafficking-Related Sanctions
Under the Trump Administration, Treasury has imposed
Since 2005, pursuant to procedures in the Foreign Relations
sanctions on an additional 91 Venezuelan officials,
Authorization Act, FY2003 (P.L. 107-228, §706; 22 U.S.C.
including President Maduro; his wife, Cecilia Flores, and
2291j), the President has made an annual determination that
son, Nicolás Maduro Guerra; Executive Vice President
Venezuela has failed demonstrably to adhere to its
Delcy Rodriguez; Diosdado Cabello (Socialist party
obligations under international narcotics agreements.
president); eight supreme court judges; the leaders of
President Trump made the most recent determination for
Venezuela’s army, national guard, and national police; four
FY2020 in August 2019 but waived foreign aid restrictions
state governors; the director of the central bank; and the
for programs that support the interim government.
foreign minister. On May 7, 2019, Treasury lifted sanctions
against the former head of Venezuela’s intelligence service,
Treasury has imposed economic sanctions on at least 22
General Manuel Cristopher Figuera, who broke ranks with
individuals with connections to Venezuela and 27
Maduro.
companies by designating them as Specially Designated
Narcotics Traffickers pursuant to the Foreign Narcotics
Kingpin Designation Act (P.L. 106-120, Title VIII; 21
https://crsreports.congress.gov

Venezuela: Overview of U.S. Sanctions
Additional Financial Sanctions
money abroad. In April, Treasury sanctioned Venezuela’s
President Trump has imposed additional financial sanctions
central bank; in July, it sanctioned Venezuela’s military
on Venezuela because of the government’s human rights
counterintelligence agency.
abuses and antidemocratic actions. In August 2017, he
issued E.O. 13808, which prohibits access to U.S. financial
In April and in September 2019, Treasury sanctioned
markets by the Venezuelan government, including PdVSA,
companies and vessels involved in transporting Venezuelan
with certain exceptions to minimize the impact on the
oil to Cuba. Companies that have stopped those shipments
Venezuelan people and U.S. interests. In March 2018,
have been delisted. On July 3, Treasury designated Cuba’s
President Trump issued E.O. 13827 to prohibit transactions
state oil import and export company.
involving the Venezuelan government’s issuance of digital
currency, coin, or token. In May 2018, President Trump
Sanctions on the Maduro Government and
issued E.O. 13835, which prohibits transactions related to
Transactions with 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
including foreign energy companies working with PdVSA.
Maduro government. Some 22 individuals are sanctioned
To allow humanitarian assistance to the Venezuelan people,
pursuant to E.O. 13850. They include people and entities
OFAC issued licenses authorizing transactions involving
involved in a $2.4 billion currency exchange corruption
the delivery of food, agricultural commodities, and
scheme; the president of the state gold mining company;
medicine; remittances; international organizations; and
and individuals and entities that siphoned millions of
communications services. In April 2020, OFAC issued
dollars from Venezuela’s emergency food aid system.
guidance encouraging organizations delivering
humanitarian aid to Venezuela to report any sanctions-
On January 28, 2019, pursuant to E.O. 13850, Treasury
related barriers they may face so that they can be resolved.
designated PdVSA as operating in the oil sector of the
Venezuelan economy, and Secretary of the Treasury Steven
In 2020, Treasury has imposed sanctions on Rosneft
Mnuchin determined that the company was subject to U.S.
Trading S.A. and TNK Trading International S.A.,
sanctions. As a result, all property and interests in property
subsidiaries of Russia’s Rosneft state-controlled oil and gas
of PdVSA subject to U.S. jurisdiction are blocked, and U.S.
company for assisting PdVSA, a violation of U.S.
persons (companies or individuals) generally are prohibited
sanctions. On June 2, Treasury sanctioned four foreign
from engaging in transactions with the company.
shipping companies for transporting Venezuelan oil. On
June 18, Treasury sanctioned three individuals and eight
At the same time, Treasury’s Office of Foreign Assets
companies for sanctions evasion related to an alleged “oil-
Control (OFAC) issued general licenses to allow certain
for-food” program. Through the Iran sanctions framework,
transactions and activities related to PdVSA and its
Treasury sanctioned Iranian individuals and entities linked
subsidiaries, some for specified wind-down periods. OFAC
to recent shipments of Iranian petroleum products to
first authorized transactions with U.S.-based PdVSA
Venezuela in exchange for gold.
subsidiaries, PDV Holding, Inc. (PDVH) and CITGO
Holding, Inc. through July 27, 2019. In March 2019, the
Policy Considerations
general license for those entities was extended for 18
On a bipartisan basis, Congress has supported targeted
months. OFAC authorized PDVH, CITGO, and other U.S.
sanctions against Maduro officials, but opinions on broader
companies to import petroleum from PdVSA through April
sanctions vary. Some in Congress support economic
28, 2019, but payments had to be made to a blocked U.S.
sanctions as a means to pressure the Maduro government.
account. OFAC initially authorized U.S. companies with
Others, concerned about the humanitarian effects of those
operations in Venezuela involving PdVSA (including
sanctions, have called for a suspension of sanctions during
Chevron) to continue operating through July 27, 2019. An
the Coronavirus Disease 2019 (COVID-19) pandemic.
amended April 2020 license only allows transactions
necessary for the maintenance of “essential operations” or
In December 2019, Congress enacted P.L. 116-94, an act
the “wind down of operations” by December 1, 2020.
that includes provisions from the VERDAD Act (S. 1025)
that, among other measures, extend sanctions regarding
In March 2019, Treasury sanctioned the Moscow-based
corruption and undemocratic actions through 2023.
Evrofinance Mosnarbank (owned by Russia and Venezuela)
for helping PdVSA funnel revenue from oil sales. Treasury
See U.S. Department of the Treasury, “Venezuela-Related
then sanctioned Venezuela’s state-owned gold sector
Sanctions,” at https://www.treasury.gov/resource-center/
company, Minerven, for using illicit gold operations to
sanctions/programs/pages/venezuela.aspx. Also see CRS In
support Maduro. It also sanctioned the state-affiliated
Focus IF10230, Venezuela: Political Crisis and U.S. Policy;
Venezuelan Economic and Social Development Bank and
and CRS Report R44841, Venezuela: Background and U.S.
subsidiaries that the Maduro government uses to move
Relations.
https://crsreports.congress.gov

Venezuela: Overview of U.S. Sanctions

Clare Ribando Seelke, Specialist in Latin American
Affairs
IF10715


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