In response to series of events which happened through out 2014 in Venezuela, the  U.S. Congress in December of 2014, passed Venezuela Defense of Human Rights and Civil Society Act of 2014. The act required the president to sanction those in charge of cracking down the protests and those violating human rights.  Later in March of 2015, the President issued E.O. 13692, which implemented the sanctions stated in the December act as well as new designation grounds in response to the situation in Venezuela. The executive order also put in place travel bans for those listed under its authority. Those who are listed pursuant to this executive order are identified by the tag of [VENEZUELA] on the Treasury SDN list.

 

As the situation in Venezuela continued to deteriorate, President Donal Trump issued E.O. 13808 which rolled out new set of sanctions on debt and equities (similar to that of Ukraine/Russia program). The restrictions (which later become obsolete as the Gov. of Venezuela and PdVSA were listed) were: 

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(i) new debt with a maturity of greater than 90 days of Petroleos de Venezuela, S.A. (PdVSA);

(ii) new debt with a maturity of greater than 30 days, or new equity, of the Government of Venezuela, other than debt of PdVSA mentioned above;

(iii) bonds issued by the Government of Venezuela prior to the effective date of this order; or

(iv) dividend payments or other distributions of profits to the Government of Venezuela from any entity owned or controlled, directly or indirectly, by the Government of Venezuela.  

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In order to cancel the effect of the U.S. sanctions the Venezuelan Government created a form of digital currency called Petro (₽) in February of 2018. A month later, the U.S. President issued E.O.13827 and prohibited any transactions relating to any digital currency, digital coin, or digital token, that was issued by, for, or on behalf of the Government of Venezuela. E.O. 13827 foiled the attempt of Venezuelan Government to evade U.S. sanctions. Furthermore, in May 2018, in order to limit the access of the Venezuela Government to capital, the United States increased the restrictions against debts owed to the Government of Venezuela by issuing E.O. 13835.

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In November of 2018, another executive order was issued (E.O. 13850) which provided for additional grounds for designations. This authority has been used several times to designated those non-Venezuelan persons who were supporting the Government of Venezuela. A good example of this was the designation of Rosneft Trading S.A.. Such designated persons are identified with the tag of [VENEZUELA-EO13850]. 

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In January 2019, when Nicolas Maduro Sworn in for the second term U.S. government took two steps. One was issuance of E.O. 13857 which expanded slightly the definition of Government of Venezuela to include Mr. Maduro and his regime. The other step, which was a major one, was designation PdVSA as and SDN. 

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In its latest step the United States blocked the assets of the Government of Venezuela and provided some additional designation grounds for those assisting the Government of Venezuela. (E.O. 13884)

 

A feature which distinguishes Venezuela program with the tother programs administered by OFAC is the existence of several General Licenses. There are currently dozens of General Licenses in place which is indicative of the proximity of the Venezuelan economy (especially oil sector) to the U.S. market. These licenses are constantly being updated. To get the latest list of applicable General licenses you can check here. 

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Regulations on Venezuela Sanctions are codified under section 591 of 31 C.F.R.