Freehill, Hogan and Mahar have just issued the latest client alert on Venezuelan Sanctions. The full alert can be viewed here
On January 28, 2019 the U.S. designated Petroleos de Venezuela S.A. (“PdVSA”) to the U.S. Specially Designated Nationals List (“SDN List”). The immediate effect was that U.S. persons were generally prohibited from engaging in any transactions with PdVSA and all of PdVSA’s property and interest in property in the United States were blocked. These restrictions also applied to any entity 50% or more owned by PdVSA.
U.S. SDN List, in and of itself, does not have extraterritorial effect; that is, the naming of an entity to the SDN List does not automatically mean that non-U.S. persons are subject to sanctions if they deal with that entity. However, depending on the authorization under which the designation to the SDN List was made, or depending on whether certain other sanctions legislation incorporates the SDN List, the naming of an entity to the SDN List can impact non-U.S. persons.