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.