On Monday, 9 March 2015, President Obama signed an executive order declaring a national emergency to deal with the threat to US national security and foreign policy posed by "the Government of Venezuela's erosion of human rights guarantees, persecution of political opponents, curtailment of press freedoms, use of violence and human rights violations and abuses in response to antigovernment protests, and arbitrary arrest and detention of anti-government protestors, as well as the exacerbating presence of significant public corruption."
The executive order imposes sanctions on seven Venezuelan officials. The sanctions regime freezes US assets belonging to these individuals, bans them from entering the US, and restricts donations to and transactions with them. Pursuant to the executive order, the Office of Foreign Assets Control (OFAC) within the Treasury Department has already added the seven individuals to its Specially Designated Nationals (SDN) list.
Significantly, the executive order provides that the sanctions regime may be imposed upon additional persons determined by the Secretary of the Treasury to meet certain specified criteria, such as persons responsible for or complicit in actions or policies that undermine democratic processes or institutions in Venezuela or other persons who are current or former officials of the Government of Venezuela. Thus, the identification of the seven Venezuelan officials may be a harbinger of further designations to come.
For more information or sanctions-related advice, please contact Scott Balber, Susannah Cogman or Jonathan Cross.
Key contacts
Andrew Cannon
Partner, Global Co-Head of International Arbitration and of Public International Law, London
Christian Leathley
Partner, Co-Head of the Latin America Group, Co-Head of the Public International Law Group, US Head of International Arbitration, London
Disclaimer
The articles published on this website, current at the dates of publication set out above, are for reference purposes only. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action.