Introduction The United States first imposed sanctions targeting the Venezuelan government in 2015. Both the US and EU have designated individuals associated with the regime. The US measures against the government of Venezuela were significantly extended in January 2019 to target PdVSA. While initially thought to have limited direct impact on non-US persons engaged in trade with no US nexus, statements emerging from the US administration during March and April 2019 included warnings that non-US persons dealing with PdVSA might be exposed even in the absence of a US nexus.  ( see US Treasury press release ). An International Group Circular on US Sanctions against the Government of Venezuela and PdVSA was published on 12 September 2019 . A further significant development took place with the publication of Executive Order 13884 on 5 August 2019 , together with  amended and new FAQs and general licenses .  All property of the Government of Venezuela in the US or within the control or possession of US persons is blocked. The term "Government of Venezuela" is widely defined and includes PdVSA (see E.O. 13850, as amended by E.O. 13857, Sec 6(d)). As with earlier measures, the question arises of application to non-US persons – see EO 13850 Sec 1(a)(iii) below.  E.O. 13884 authorises asset freezing on "any person" determined to (i) have materially assisted or supported any person or entity whose property is blocked pursuant to the E.O., or (ii) be owned or controlled by or to have acted on behalf of any such person or entity. The carriage of cargo may well fall within the scope of material assistance. The intention behind the E.O. therefore is to expose non-US persons and entities to US sanctions - or at the very least to deter them from doing business with the Maduro regime. It should be noted that sanctions regulations are subject to change without notice and with immediate effect. The situation in Venezuela is volatile and the US, EU and other Sta