New US Executive Order prohibiting transactions with Venezuelan digital currencies

Trump5.jpgUS President Trump has issued a new Executive Order, which takes additional steps to address the situation in Venezuela. In particular, it prohibits US persons from transacting/dealing with “any digital currency, digital coin, or digital token, that was issued by, for, or on behalf of the Government of Venezuela on or after January 9, 2018”. The “Government of Venezuela” is stated as including the Central Bank of Venezuela, as well as the state-owned oil and natural gas company, Petroleos de Venezuela, S.A. (PdVSA).

Acting concurrently, OFAC has released new FAQs related to this Executive Order (which confirms that both the ‘petro’ and the ‘petro-gold’ fall within the Executive Order), as well as a set of new Digital Currency-related FAQs. Furthermore, OFAC has designated 4 current or former Venezuelan government officials pursuant to Executive Order 13692 (asset freezes imposed), namely: Willian Antonio Contreras (‘Vice Minister of Internal Commerce’), Nelson Reinaldo Lepaje Salazar (‘Head of the Office of the National Treasury’), Americo Alex Mata Garcia (‘Alternate Director on the Board of Directors of the National Bank of Housing and Habitat’), and Carlos Alberto Rotondaro Cova (‘Former President of the Board of Directors of the Venezuelan Institute of Social Security’). See OFAC Notice here, and US Treasury press release here.

We previously reported that OFAC had published an FAQ relating to US person involvement in the Venezuelan government’s digital currency – the petro – which was launched in February 2018.

This entry was posted in USA, Venezuela by Michael O'Kane. Bookmark the permalink.

About Michael O'Kane

Michael O’Kane is a partner and Head of the Business Crime team at leading UK firm Peters & Peters. Described as ‘first-rate’ (Legal 500 2012), he “draws glowing praise from commentators” (Chambers 2013) for handling the international aspects of business crime, including sanctions, extradition and mutual legal assistance. Called to the Bar in 1992 and prior to joining Peters & Peters he was a senior specialist prosecutor at the Crown Prosecution Service Headquarters(CPS). At CPS HQ he was a key member of a small specialist unit responsible for the prosecution of serious and high profile fraud, terrorist and special interest criminal matters including the Stansted Airport Afghan hijacking and the prosecution of Paul Burrell (Princess Diana’s butler). Michael joined Peters & Peters in 2002. He became a partner in May 2004, and Head of the Business Crime team in May 2009. Since joining Peters & Peters, Michael has dealt with a wide range of business crime matters. He has particular expertise in international sanctions, criminal cartels, extradition, corruption, mutual legal assistance, and FSA investigations. Described as“ an influential practitioner in fraud and regulatory work, so much so that he is top of the referral lists of many City firms for independent advice for directors” (The Lawyer’s Hot 100 2009), he was recognised as one of the UK’s most innovative lawyers in the 2011 FT Innovative Lawyer Awards and included in the list of the UK's leading lawyers in 'The International Who's Who of Asset Recovery 2012. In 2012 he was the winner of the Global Competition Review Article of the Year. Michael regularly appears on television and radio to discuss his specialist areas and he is the author of the leading textbook on the UK Criminal Cartel Offence “The Law of Criminal Cartels-Practice and Procedure” (Oxford University Press 2009). Recent/Current Sanctions Work • Representing 109 individuals and 12 companies subject to designation by the European Council under targeted measures imposed against Zimbabwe. This is the largest and most complex collective challenge to a sanctions listing ever brought before the European Court. • Acting for a former Egyptian Minister and his UK resident wife, challenging their designation by the European Council of Ministers under targeted measures brought against former members of the Egyptian Government. • Advising a company accused in a UN investigation report to have breached UN sanctions imposed in relation to Somalia. • Advising a UK company in relation to ongoing commercial relationships with an Iranian company listed under both EU and UN sanctions. • Advising an individual in relation to a UK investigation for alleging breaching nuclear export controls.

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