On June 2, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four non-U.S. companies and four crude oil tankers for operating in the oil sector of the Venezuelan economy, pursuant to Executive Order 13850. Specifically, OFAC sanctioned the four companies and four vessels for lifting oil from Venezuelan ports, demonstrating the risk that even non-U.S. companies face doing business in the Venezuelan oil sector. The identifying information for the sanctioned companies and vessels is located here.

In short, the U.S. is continuing to focus on the maritime industry, and in particular, non-U.S. companies and vessels that do business with the Government of Venezuela. As such, even non-U.S. companies face risk operating in certain sectors of the Venezuelan economy, including the lifting and transport of Venezuelan crude oil from Petroleos de Venezuela (PdVSA) or other companies owned by, or acting on behalf of, the Government of Venezuela.

We will continue to closely monitor developments in this space. If you have any questions or concerns about U.S. sanctions, please contact Bruce G. Paulsen (212-574-1533), Andrew S. Jacobson (212-574-1477), or Noah S. Czarny (212-574-1642) at Seward & Kissel’s Sanctions Practice Group.