Overview
UN Sanctions
There are no UN sanctions on Venezuela.
EU Sanctions
In 2017 the EU adopted sanctions in response to the “deterioration of democracy, the rule of law and human rights” in Venezuela. These are still in place; an arms embargo, travel restrictions and an asset freeze on those responsible for serious human rights violations or abuses or the repression of civil society and democratic opposition, and those whose actions, policies or activities otherwise undermine democracy or the rule of law in Venezuela by Council Regulation (EU) 2017/2063 and Council Decision (CFSP) 2017/2074.
UK Sanctions
UK sanctions are in the Venezuela (Sanctions) (EU Exit) Regulations 2019 – an arms embargo, asset freezes, and travel bans.
US Sanctions
The US first imposed Venezuela sanctions in 2005/2006 in response to Venezuela’s alleged lack of cooperation on US anti-drug and counter-terrorism efforts.
Since 2005, pursuant to procedures in the Foreign Relations Authorization Act FY 2003, the President has made an annual determination that Venezuela has failed to adhere to its obligations under international narcotics agreements. And since 2006, the Secretary of State has made an annual determination that Venezuela is not “cooperating fully with United States anti-terrorism efforts” pursuant to Section 40A of the Arms Export Control Act. As a result, the US prohibits all US commercial arms sales and retransfers to Venezuela.
In response to increasing repression in Venezuela, President Obama issued E.O. 13692 in 2015, which targets (for asset blocking and visa restrictions) those involved in actions or policies undermining democratic processes or institutions; serious human rights abuses, prohibiting, limiting, or penalizing freedom of expression or peaceful assembly, and public corruption.
In 2017/ 2018, President Trump issued E.O. 13808, which prohibited access to U.S. financial markets by the Venezuelan government, including state energy company Petróleos de Venezuela, S.A (PdVSA), E.O. 13827 which prohibits transactions involving the Venezuelan government’s issuance of digital currency, coin, or token, and E.O. 13835, which prohibits transactions related to purchasing Venezuelan debt and any debt owed to Venezuela pledged as collateral.
In 2018, President Trump issued E.O. 13850, a framework to block the assets of, and prohibit certain transactions with, any person determined by the Secretary of the Treasury to operate in sectors of the economy or to engage in corrupt transactions with the Maduro government.
In 2019, President Trump issued EO 13884, blocking the property and interests of the Maduro government in the United States and within the control of U.S. persons.
The US has issued various Venezuela general licences, including to allow continued operations with PdVSA in certain circumstances and by certain entities.
Current EU Sanctions
In 2017 the EU adopted sanctions in response to the “deterioration of democracy, the rule of law and human rights” in Venezuela. These are still in place; an arms embargo, travel restrictions and an asset freeze on those responsible for serious human rights violations or abuses or the repression of civil society and democratic opposition, and those whose actions, policies or activities otherwise undermine democracy or the rule of law in Venezuela by Council Regulation (EU) 2017/2063 and Council Decision (CFSP) 2017/2074.
- Legislation
- Sanctions List
Annex IV to Council Regulation (EU) 2017/2063
- Guidance
- Judgments
-
T-65/18 Venezuela v Council
-
T-35/19 Benavides Torres
-
T-554/18 Hernández Hernández
-
T-552/18 Moreno Reyes
-
T-551/18 Oblitas Ruzza
-
T-550/18 Harrington Padrón
-
T-249/18 Saab Halabi
-
T-248/18 Cabello Rondón
-
T-247/18 Lucena Ramírez
-
T-245/18 Benavides Torres
-
T-553/18 Rodríguez Gómez
-
C-872/19 P Venezuela
-
T-65/18 Bolivarian Republic of Venezuela
-
Current UK Sanctions
UK sanctions are in the Venezuela (Sanctions) (EU Exit) Regulations 2019 – an arms embargo, asset freezes, and travel bans.
- Legislation
- Sanctions List
- Guidance
- Judgments
-
Banco San Juan Internacional Inc v Petroleos De Venezuela SA [2020] EHWC 2937
-
Current US Sanctions
The US first imposed Venezuela sanctions in 2005/2006 in response to Venezuela’s alleged lack of cooperation on US anti-drug and counter-terrorism efforts.
Since 2005, pursuant to procedures in the Foreign Relations Authorization Act FY 2003, the President has made an annual determination that Venezuela has failed to adhere to its obligations under international narcotics agreements. And since 2006, the Secretary of State has made an annual determination that Venezuela is not “cooperating fully with United States anti-terrorism efforts” pursuant to Section 40A of the Arms Export Control Act. As a result, the US prohibits all US commercial arms sales and retransfers to Venezuela.
In response to increasing repression in Venezuela, President Obama issued E.O. 13692 in 2015, which targets (for asset blocking and visa restrictions) those involved in actions or policies undermining democratic processes or institutions; serious human rights abuses, prohibiting, limiting, or penalizing freedom of expression or peaceful assembly, and public corruption.
In 2017/ 2018, President Trump issued E.O. 13808, which prohibited access to U.S. financial markets by the Venezuelan government, including state energy company Petróleos de Venezuela, S.A (PdVSA), E.O. 13827 which prohibits transactions involving the Venezuelan government’s issuance of digital currency, coin, or token, and E.O. 13835, which prohibits transactions related to purchasing Venezuelan debt and any debt owed to Venezuela pledged as collateral.
In 2018, President Trump issued E.O. 13850, a framework to block the assets of, and prohibit certain transactions with, any person determined by the Secretary of the Treasury to operate in sectors of the economy or to engage in corrupt transactions with the Maduro government.
In 2019, President Trump issued EO 13884, blocking the property and interests of the Maduro government in the United States and within the control of U.S. persons.
The US has issued various Venezuela general licences, including to allow continued operations with PdVSA in certain circumstances and by certain entities.
- Legislation
Venezuela Defence of Human Rights and Civil Society Act of 2014
Venezuela Sanctions Regulations
EO 13884 – Blocking Property of the Government of Venezuela – (August 5, 2019)
EO 13857 – Taking Additional Steps to Address the National Emergency With Respect to Venezuela (January 25, 2019)
EO 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela (November 1, 2018)
EO 13835 – Prohibiting Certain Additional Transactions with Respect to Venezuela (May 21, 2018)
EO 13827 – Taking Additional Steps to Address the Situation in Venezuela (March 19, 2018)
EO 13808 – Imposing Additional Sanctions with Respect to the Situation in Venezuela (August 24, 2017)
EO 13692 – Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela (March 8, 2015)
- Sanctions List
Search “Venezuela” on the OFAC SDN List
- Guidance
- US General Licences
- Venezuela General License 2A – Authorizing Certain New Debt, New Equity, and Securities Transactions Involving PDV Holding, Inc. and CITGO Holding, Inc.
- Venezuela General License 3I – Authorizing Transactions Related to, Provision of Financing for, and Other Dealings in Certain Bonds
- Venezuela General License 4C – Authorizing Certain New Debt Transactions and Other Transactions Involving Certain Blocked Persons Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates
- Venezuela General License 5O – Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After August 13, 2024
- Venezuela General License 7C – Authorizing Certain Activities Involving PDV Holding, Inc. and CITGO Holding, Inc.
- Venezuela General License 8M – Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities
- Venezuela General License 9H – Authorizing Transactions Related to Dealings in Certain Securities
- Venezuela General License 10A – Authorizing the Purchase in Venezuela of Refined Petroleum Products from Petróleos de Venezuela, S.A. (PdVSA)
- Venezuela General License 15C – Authorizing Transactions Involving Certain Banks for Certain Entities
- Venezuela General License 16C – Authorizing Maintenance of U.S. Person Accounts and Noncommercial, Personal Remittances involving Certain Banks
- Venezuela General License 18A – Authorizing Certain Transactions Involving Integración Administradora de Fondos de Ahorro Previsional, S.A.
-
Venezuela General License 21 – Entries in Certain Accounts for Normal Service Charges and Payments and Transfers to Blocked Accounts in U.S. Financial Institutions Authorized
- Venezuela General License 22 – Venezuela’s Mission to the United Nations
- Venezuela General License 23 – Third-country Diplomatic and Consular Funds Transfers Authorized
- Venezuela General License 24 – Certain Transactions Involving the Government of Venezuela Related to Telecommunications and Mail Authorized
- Venezuela General License 25 – Exportation of Certain Services, Software, Hardware, and Technology Incident to the Exchange of Communications over the Internet Authorized
- Venezuela General License 26 – Emergency and Certain Other Medical Services Authorized
- Venezuela General License 27 – Certain Transactions Related to Patents, Trademarks, and Copyrights Authorized
- Venezuela General License 29 – Certain Transactions Involving the Government of Venezuela in Support of Certain Nongovernmental Organizations’ Activities Authorized
- Venezuela General License 30A – Authorizing Certain Transactions Necessary to Port and Airport Operations
- Venezuela General License 31B – Certain Transactions Involving the IV Venezuelan National Assembly and Certain Other Persons
- Venezuela General License 32 – Authorizing Certain Transactions Related to Personal Maintenance of Individuals who are U.S. Persons Residing in Venezuela
- Venezuela General License 33 – Authorizing Overflight Payments, Emergency Landings, and Air Ambulance Services
- Venezuela General License 34A – Authorizing Transactions Involving Certain Government of Venezuela Persons
- Venezuela General License 35 – Authorizing Certain Administrative Transactions with the Government of Venezuela
- Venezuela General License 39B – Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19)
- Venezuela General License 40B – Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela
- Venezuela General License 41 – Authorizing Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela
- Venezuela General License 42 – Authorizing Certain Transactions Related to the Negotiation of Certain Settlement Agreements with the IV Venezuelan National Assembly and Certain Other Persons
- Venezuela General License 43A – Authorizing the Wind Down of Transactions Involving CVG Compania General de Mineria de Venezuela CA
- Venezuela General License 44A – Authorizing the Wind Down of Transactions Related to Oil or Gas Sector Operations in Venezuela
- Venezuela General License 45B – Authorizing Certain Repatriation Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A.
- Judgments
-
Bello v Gacki, No. 23-5036
-
Siemens Energy, Inc. v. PDVSA No. 22-0047
-
Other Countries Sanctions
- Judgments
-
Gomez v Canada (Attorney General) 2021 FC 1300
-
