By: Danielle McClellan
On July 10, 2015 the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued regulations (part 591) to implement a previous Executive Order.
Compliance Summary: The regulations prohibit US persons (not including foreign subsidiaries of US companies) from participating in activities with listed Venezuelan parties. For the most part, US persons will be able to comply with this rule if they screen against the prohibited parties list.
At this time the regulations are being published in an abbreviated format in order to provide immediate guidance to the public. OFAC will provide part 591 with a comprehensive set of regulations which will include more guidance related to definitions and general licensing information. Part 591 is being issued after Executive Order 13692 (Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela) was released on March 8, 2015. The goal of the Executive Order is to target sanctions on certain persons responsible for significant acts of violence or serious human rights abuses against anti-government protesters and any other persons being prosecuted for exercising their freedom of expression or assembly in Venezuela.
Federal Register Notice: http://www.gpo.gov/fdsys/pkg/FR-2015-07-10/pdf/2015-16782.pdf