US Imposes Sanctions on Oil Traders Aiding Maduro Regime

Key Takeaways:

  • The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned four companies for operating in Venezuela’s oil sector.
  • Four associated oil tankers have been identified as blocked property, including NORD STAR, ROSALIND, DELLA, and VALIANT.
  • The sanctions aim to prevent the Maduro regime from profiting from exporting oil and to disrupt its ability to generate revenue for its destabilizing operations.
  • U.S. persons are prohibited from engaging in transactions involving the designated or blocked persons, and violations may result in civil or criminal penalties.
  • The ultimate goal of the sanctions is to bring about a positive change in behavior and to prevent the Maduro regime from engaging in sanctionable activities.

Introduction to Sanctions
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has taken significant action against the Maduro regime in Venezuela by sanctioning four companies for operating in the country’s oil sector. The sanctions, which were announced today, also identify four associated oil tankers as blocked property. This move is part of a broader effort by the U.S. government to prevent the Maduro regime from profiting from exporting oil and to disrupt its ability to generate revenue for its destabilizing operations. The sanctions are a clear signal that those involved in the Venezuelan oil trade continue to face significant risks and that the U.S. government is committed to implementing President Trump’s campaign of pressure on the Maduro regime.

Background on Venezuelan Oil Sector
The Venezuelan oil sector has been a key target of U.S. sanctions in recent years. On January 28, 2019, OFAC designated Venezuela’s state-run oil company, Petroleos de Venezuela, S.A. (PDVSA), pursuant to Executive Order (E.O.) 13850 for operating in the oil sector of the Venezuelan economy. This was followed by additional action on August 5, 2019, when President Trump took steps to block PDVSA pursuant to E.O. 13884. Today’s sanctions complement other recent OFAC actions taken against the Maduro regime, including sanctions against PDVSA-linked officials, associates, and vessels on December 11 and December 19. The sanctions are designed to prevent the Maduro regime from using the oil sector to generate revenue and to disrupt its ability to engage in sanctionable activities.

Sanctioned Entities and Vessels
The following entities are being sanctioned today, and four vessels are being blocked for being property in which these entities have an interest. NORD STAR (IMO: 9323596), whose registered owner is Corniola Limited and whose ship manager and operator is Krape Myrtle Co LTD, has transported Venezuelan oil. OFAC is designating Corniola Limited and Krape Myrtle Co LTD pursuant to E.O. 13850 for operating in the oil sector of the Venezuelan economy and is identifying NORD STAR as blocked property in which Corniola Limited and Krape Myrtle Co LTD have an interest. Similarly, ROSALIND a.k.a. LUNAR TIDE (IMO: 9277735), whose registered owner is Winky International Limited, has transported Venezuelan oil. OFAC is designating Winky International Limited pursuant to E.O. 13850 for operating in the oil sector of the Venezuelan economy and is identifying ROSALIND as blocked property in which Winky International Limited has an interest.

Sanctions Implications
As a result of today’s action, all property and interests in property of the designated or blocked person described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons. Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis.

Enforcement and Removal from Sanctions List
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons List (SDN List), but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, or to submit a request, please refer to OFAC’s guidance on Filing a Petition for Removal from an OFAC List. The U.S. government is committed to enforcing its sanctions and to preventing the Maduro regime from engaging in sanctionable activities. The sanctions announced today are an important step in this effort and demonstrate the U.S. government’s commitment to implementing President Trump’s campaign of pressure on the Maduro regime.

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