The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has imposed sanctions to Venezuela, highlighting the intention of the US authorities against Venezuela. The sanctions apply to non-US persons and deem that any ship involved in the petroleum trades between Venezuela and Cuba is undertaking sanctionable activity with an attendant risk of being designated.
In fact, recently, the US designated two companies that operate in the oil sector of the Venezuelan economy, pursuant to E.O. 13850, as amended. OFAC has also identified two vessels, which transported oil from Venezuela to Cuba, as blocked property owned by the two companies.
In addition, the Republic of the Marshall Islands (RMI) Maritime Administrator issued an advisory informing that the US has designated Petróleos de Venezuela, S.A. (PdVSA) as a Specially Designated National and Blocked Person (SDN) and therefore RMI will be unable to provide services to vessels linked to PdVSA.
On 28 January 2019, the US put the state-owned oil and natural gas company in its SDN list, which means that US persons may not engage in any dealings with the company or any of its direct or indirect subsidiaries. The sanction only applies to US persons at this time.