Venezuela Sanctions Update: United States Sanctions the State-Owned Oil Company, Petróleos de Venezuela, S.A., in Effort to Further Pressure the Maduro Regime and to Protect State Assets for the People of Venezuela

Sullivan & Cromwell LLP - February 5, 2019
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On January 28, 2019, the Department of the Treasury’s Office of Foreign Assets Control added Petróleos de Venezuela, S.A. (“PdVSA”), a Venezuelan state-owned oil company, to its list of Specially Designated Nationals and Blocked Persons pursuant to Executive Order 13850 (the “Designation”).  The Designation further escalates U.S. sanctions policy toward Venezuela.  Since initial steps targeting Venezuela were taken in 2015, U.S. sanctions have been implemented in a series of measures targeting President Maduro and his close associates and sources of financing for the Maduro regime.  As a result of the Designation, all property and interests in property of PdVSA (and of any entity of which PdVSA owns 50% or more) that are in the United States, or that come into the possession or control of a U.S. person, are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in unless authorized by a general or specific license.