OFAC sanctions Venezuela Central Bank ‘for operating in the financial sector’

On 17 April, the Office of Foreign Assets Control (‘OFAC’) of the US Department of the Treasury announced that it had designated Banco Central de Venezuela (Central Bank of Venezuela) ‘for operating in the financial sector’ of the Venezuelan economy.

In FAQs, OFAC says the designation will ‘not restrict the ability of U.S. persons to engage in or facilitate the provision of humanitarian assistance or non-commercial, personal remittances to Venezuela,’ and that it is  ‘committed to ensuring that humanitarian assistance and non-commercial, personal remittances can flow to the people of Venezuela.’

To that end, it says, it has issued amendments ‘to current Venezuela-related general licenses and issued a new general license to ensure that U.S. persons may continue to engage in and facilitate non-commercial, personal remittances and the provision of humanitarian assistance to the people of Venezuela.’

Regarding humanitarian transactions, it says, it has updated General License 4A ‘Authorizing New Debt Transactions and Transactions involving Certain Banks Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices or Replacement Parts and Components’  to include Banco Central de Venezuela ‘in the authorization for transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, components, or replacement parts for medical devices, to Venezuela, or to persons in third countries purchasing specifically for resale to Venezuela, provided that the exportation or reexportation is licensed or otherwise authorized by the Department of Commerce, or for items not subject to the Export Administration Regulations, is not listed under any multilateral export control regime.’

OFAC points out that it maintains ‘a specific licensing regime that can evaluate on a case-by-case basis the authorization of humanitarian activities not covered under general licenses.’

Further reading is at:
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20190417.aspx

General License 4A is at:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/venezuela_gl4b.pdf