OFAC Alert: Financial Sector of the Venezuelan Economy-Related Sanctions

On March 22, 2019, the Secretary of the Treasury Steven T. Mnuchin determined that persons operating in Venezuela’s financial sector may be designated by the Office of Foreign Assets Control (“OFAC”) pursuant to Executive Order 13850 issued on November 1, 2018 by President Donald J. Trump. This executive order authorizes OFAC to designate, in consultation with the Secretary of State, any person operating in the gold sector of the Venezuelan economy or in any other sector of the Venezuelan economy.

Consistent with the Secretary of the Treasury’s determination, OFAC added the names of the following financial institutions to its list of Specially Designated Nationals and Blocked Persons (SDN List)BANDESBanco Bandes Uruguay S.A., Banco Bicentenario del Pueblo, de la Clase Obrera, Mujer y Comunias, Banco Universal C.A.; Banco de Venezuela, S.A. y Banco Prodem S.A.Accordingly, all property or interest in property of these financial institutions within or transiting U.S. jurisdiction has been blocked. Additionally, if they are not authorized by a general or specific license issued by OFAC, U.S. persons are prohibited from engaging in transactions with these financial institutions or with entities in which they have, directly or indirectly, 50{5fd5d0c347966b9ca8e0f456e16034dfe54ed0385696705fc3c1ddd66732c056} or greater ownership interest.

On the same date, OFAC amended General License 4 “Authorizing New Debt Transactions and Transactions involving Certain Banks Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, or Replacement Parts and Components.” It also issued the following four new general licenses: i) General License 15 “Authorizing Transactions Involving Certain Banks Prohibited by Executive Order 13850 for Certain Entities”; ii) General License 16 “Authorizing Maintenance of U.S. Person Accounts and Noncommercial, Personal Remittances involving Certain Banks”; iii) General License 17 “Authorizing Certain Activities Necessary to Wind Down of Operations or Existing Contracts with Certain Banks”; iv) General License 18 “Authorizing Certain Transactions Involving Integracion Administradora de Fondos de Ahorro Previsional, S.A.”

Michael Diaz, Javier Coronado
Tel: +1 (305) 375-9220