On April 17, 2019, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had designated Banco Central de Venezuela (Banco Central), the country’s Central Bank, as subject to U.S. economic sanctions. A current director also was sanctioned; several other Banco Central management and directors previously had been designated for economic sanctions.

The designation means that all property and interest in property of Banco Central and the director and any entity that is owned, directly or indirectly, 50% or more by either of them, that are in the United States or in possession or control of the United States, are blocked and must be reported to OFAC. All dealings by U.S. persons or within the United States that involve property or an interest in property of blocked or designated persons generally are prohibited.

OFAC did issue a series of licenses to facilitate certain transactions involving Banco Central, including:

  • License to allow certain transactions between Banco Central and several international organizations, such as the International Committee of the Red Cross and the United Nations, to the extent the transactions are subject to U.S. jurisdiction.
  • License to authorize until May 17, 2019, certain actions related to the winding down of operations, contracts, or other agreements involving Banco Central that were in effect prior to April 17, 2019.
  • License to allow processing through U.S. financial institutions of noncommercial personal remittances to persons in Venezuela through Banco Central and certain other Venezuelan banks.
  • License to allow processing of certain transactions with credit card companies and money transmitters involving Banco Central and certain other Venezuelan banks.

Treasury Secretary Steven Mnuchin noted in the press release announcing the designations that “Treasury is designating the Central Bank of Venezuela to prevent it from being used as a tool of the illegitimate Maduro regime, which continues to plunder Venezuelan assets and exploit government institutions to enrich corrupt insiders.”

Additional information from OFAC on Venezuelan designations may be found here.

Other Regulation Tomorrow blog posts on the Venezuela sanctions may be found here, here and here.