Further to our News Item of 11 April 2019 the United States has designated a further nine vessels and four owning companies for involvement in the carriage of petroleum cargoes from Venezuela to Cuba. A list of these designations can be found here.
This action clearly underlines the intention of the U.S. authorities as outlined in our earlier News Item to interpret their sanctions regime against Venezuela as applying to non-U.S. persons and to deem that any vessel involved in the petroleum trades between Venezuela and Cuba is undertaking sanctionable activity with an attendant risk of being designated. Becoming a SDN does of course have grave implications for the trading and insurance cover of any designated vessel.
As previously noted there is a risk that the U.S. will likewise deem that any vessel undertaking activity involving PDVSA is engaged in the Venezuelan oil sector and consequently at risk of designation. Members are consequently reminded in the strongest possible terms to carefully consider the risks when deciding whether to engage in any trades involving PDVSA and certainly if they involve the carriage of oil or petroleum products from Venezuela to Cuba. If in doubt they should contact the Managers for further advice.