On 25 January 2019 U.S. President Trump signed an Executive Order entitled “Taking Additional Steps to Address the National Emergency with Respect to Venezuela.” This Executive Order broadens the definition of the term “Government of Venezuela” to include anyone that has acted, or allegedly acted, either directly or indirectly, for or on behalf of the Government of Venezuela, including members of the Maduro regime.
Furthermore, on 28 January 2019 the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) and updated its List of Specially Designated Nationals and Blocked Persons (“SDN List”) accordingly.
OFAC is also amending General License 3 (“Authorizing Transactions Related to, Provisions of Financing for, and Other Dealings in Certain Bonds”) and newly issuing the following General Licenses in connection with the designation of PdVSA:
General License 7: Authorizing Certain Activities with PDV Holding, Inc. and CITGO Holding, Inc.
General License 8: Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Prohibited by Executive Order 13850 for Certain Entities Operating in Venezuela