Further to our News Item of 30 January 2019, there has been some clarification from OFAC on the recently-implemented General Licences and Executive Orders by way of FAQs which can be found by clicking here.
It is now apparent that the PDVSA-related sanctions are applicable only to U.S. entities and U.S. persons both in the United States and abroad. Subject to any further clarification from OFAC, it appears unlikely that the current sanctions will impact on non-U.S. persons dealing with PDVSA. Members who are not U.S. persons are therefore free to trade with and carry PDVSA cargoes, although not to the United States after 28 April 2019. However, in order to avoid potential issues with U.S. banks blocking or delaying payments in U.S. Dollars relating to PDVSA trades Members are advised to structure their trades in an alternative, non-Dollar currency. Payments using the Venezuelan cryptocurrency the “Petro” should also be avoided.
As always, Members with specific questions concerning these measures and any other sanctions matters should contact the Managers. General guidance on sanctions can also be found on the Club's sanctions webpages.