Circular issued by International Group clubs Home / News / Circulars / United States Sanctions on Venezuela Circulars – P&I – No: 2666/2021 United States Sanctions on Venezuela 9 February, 2021 Circular issued by International Group clubs This Circular provides information on the recent designation by the Government of the United States of Venezuela’s Maritime Authority (Instituto Nacional de los Espacios Acuaticos – “INEA”). INEA was designated under Executive Order 13850 for operating in the oil sector of Venezuela and providing assistance to Venezuela’s state-owned oil company, PdVSA. The designation led to understandable confusion among shipowners who were exposed to the possibility that they would offend certain provisions of E.O. 13850 by utilizing or paying for services provided by INEA at Venezuela ports on voyages unrelated to the oil or other targeted sectors. To address this side effect of INEA’s designation, OFAC has now issued General License 30A appended to this circular for information. Background Prior to being designated to the SDN list, INEA was blocked as a “Government of Venezuela” entity under E.O. 13884. This meant that, absent U.S. Government authorisation, U.S. persons were prohibited from engaging in virtually any transaction that involves INEA, either directly or indirectly.  As such, U.S. persons (including U.S. banks) were prohibited from engaging in transactions involving INEA once E.O. 13884 was issued, absent the relevant authorisation. General License 30 provided that authorisation for ordinary port expenses, e.g., tugs, port dues, etc., such that transactions involving INEA associated with ordinary port usage and expenses were permissible, provided the trade was not sanctionable. The designation of INEA to the SDN list created confusion as to whether the authorisation of GL 30 would still apply. GL 30 stated that it did not authorise activities or transactions prohibited by E.O. 13850, the authority under which INEA is now d