Further to our Web update of 9th April 2019 on Venezuelan Sanctions, Members whose trade involves Venezuela should be aware that OFAC has recently added to the SDN list four ship owning companies and nine vessels, for alleged involvement in carriage of petroleum cargoes from Venezuela to Cuba. The designations are listed at the following link: https://home.treasury.gov/news/press-releases/sm653

These designations provide clear evidence that the U.S. authorities may interpret sanctions to apply to non-US persons. Clearly that risk is very high in relation to carriage of oil or petroleum products from Venezuela to Cuba. Informal contacts with the U.S authorities suggest that imports of gasoline to Venezuela could also be viewed as high risk if regarded as being supportive of a sanctioned entity. However, any voyages involving PDVSA or other sanctioned entities must be considered to involve some degree of sanctions risk and Members are therefore reminded to make careful assessment of risks and potential consequences before undertaking voyages or commitments in relation to Venezuela.