On 20th February, a Client Alert from Baker McKenzie clarifies and summarises the US sanctions that apply to CITGO Holding Inc (and its subsidiaries), PDV Holding Inc (and its subsidiaries), Nynas AB (and its subsidiaries) and all other PdVSA subsidiaries.  It points out that the designation of PDVSA as an SDN added to an already complex sanctions compliance landscape where entities owned by the Government of Venezuela or by PdVSA are concerned.  Although entities 50% or more owned by PdVSA would normally be subject to the same SDN restrictions as PdVSA itself, the current US restrictions on dealings with direct and indirect PdVSA subsidiaries are not so straightforward due to the various Executive Orders, authorisations, general licences, and published guidance from OFAC.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: