INSIGHT: Venezuela Sanctions in Marine Insurance P&I Club News 17/02/2026 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 States may expand or remove sanctions to reflect political developments. Since the designation of PdVSA, the US has continued to make regular additions to the SDN list. US The United States first imposed sanctions targeting the Venezuelan government in 2015. The US measures against the government of Venezuela were significantly extended in January 2019 with issue of Executive Order 13857 which extended the scope of Executive Order 13850 by designating Petroleos de Venezuela, S.A (PdVSA) as a Specially Designated National (“SDN”). This includes entities in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, subject to some limited relief for PdVSA’s US subsidiaries CITGO and PDV Holdings. The designation prohibits US persons from engaging in transactions with PdVSA or its subsidiaries unless they are able to bring themselves within the scope of a General License. All PdVSA property which is subject to US jurisdiction is blocked. The designation does not on the face of it have extraterritorial effect, but non-US persons may be affected in a number of ways: The US government can impose sanctions an “any person” (including non-US persons) determined to have “…materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of… any person whose property and interests in property are blocked pursuant to this order.” (EO 13850 Section 1(a)(iii)). Additiona