On August 5, 2019, the National Executive of the United States of America (U.S.) administration signed a new Executive Order against the Government of Venezuela, which was numbered 13,884.
This new order adds to a group of six other similar documents that have been adopted by the U.S. Government since 2015. The novelty of this new instrument is mainly summarized in the blocking of assets of the Venezuelan Government in the territory of the United States.
Our analysis of sanctions
Alan Aldana & Abogados has conducted an analysis of this Executive Order, to clarify the term "Government of Venezuela" and its scope.
Pursuant to section 6 (d) of the Executive Order object of our analysis, such term includes the State and Government of Venezuela, political subdivisions, meaning federal entities (States) and Municipalities, agencies, the Central Bank of Venezuela and Petróleos de Venezuela S.A. as well as any entity in which the Government of Venezuela has ownership or an interest equivalent to fifty percent (50%). (emphasis added).
On this last point, it is worth clarifying, that OFACIn 2014, it published a guide in which it expands for a better understanding, everything related to the control or ownership of the assets of blocked persons.
