A comprehensive alert from law firm Wilmer Hale on 29th January details the sanctions, and the various licences, announced by the US Treasury, which described PdVSA as a “vehicle for corruption” and the “primary source of Venezuela’s income and foreign currency”. The designation, it explains, creates new restrictions and compliance challenges for companies that have financial or commercial ties to Venezuela or to PdVSA, including through their portfolio holdings. Because PdVSA is an SDN, all its property and property interests that are in the US or under the possession or control of a US person must be blocked and may not be part of any transactions or dealings with a US nexus. The licences amend existing authorisations and extend limited relief from broad prohibitions – but only in narrow circumstances that involve specific parties, specific periods of duration and specific types of transactions.
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