Information as of: 31st July 2022

British Overseas Territories: Anguilla; British Antarctic Territory; British Indian Ocean Territory; Cayman Islands; Falkland Islands; Montserrat; Pitcairn, Henderson, Ducie and Oeno Islands; St Helena, Ascension and Tristan da Cunha; South Georgia and the South Sandwich Islands; the Sovereign Base Areas of Akrotiri and Dhekelia in the Island of Cyprus; Turks and Caicos Islands; and Virgin Islands.

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US Effective from 18 Dec 2014, allows imposition of asset freezes and visa bans on any person who perpetrated or was responsible for: acts of violence or serious human rights abuses against persons associated with anti-government protests, arrest or prosecution of persons exercising legitimate exercise of freedom of expression or assembly or knowingly assisted or provided significant financial, material or technological support for the commission of such acts. Regulations issued in Aug 2015 to implement the Venezuela Defence of Human Rights and Civil Society Act of 2014 and Executive Order 13692 of 8 Mar 2015.  On the 5 Aug 2019 pursuant of EO 13692 OFAC issued an amendment under EO13884 which takes additional steps to block all property and interests in property of the Venezuelan government within the jurisdiction of the US, and to restrict entry into the US of those affiliated with the Venezuelan government.  Restrictions stated under EO13692 and EO13884 were extended until 5 March 2021. Effective 13 Feb 2017 Executive Vice-President of Venezuela designated under Kingpin Act in addition to his associated companies. 25 Aug 2017, EO 13808 imposes additional sanctions that prohibit dealings in new debt and equity issued by the Venezuelan Government and its state oil company, certain existing bonds and dividend payments to, and the purchase of securities from, the Venezuelan Government. Several general licences issued, including for financing most commercial trade, 30-day wind-down periods, and the financing of humanitarian goods. EO 13827 on 19 Mar 2018 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 9 January 2018. EO 13835 issued 21 May 2018 prohibits the purchase of any debt owed to the Venezuelan government; any debt owed to the Venezuelan government that is pledged as collateral after 21 May 2018; and the sale, transfer, assignment, or pledging as collateral by the Venezuelan government of any equity interest in any entity in which the Venezuelan government has a 50% or greater ownership interest. 19 Jul 2018 General Licence 5 issued to allow certain transactions in relation to Petroleos de Venezuela. 7 Feb 2020 OFAC designated Venezuela state owned airline Consorcio Venezolano De Industrias Aeronauticas Y Servicios Aereos, S.A. also known as Conviasa. OFAC issued updated Venezuela related FAQs. Of particular note FAQ 914 confirmed that non-US people/entities would not be sanctioned by the US for engaging in transactions or activities authorised by General Licence 40; which authorises some transactions that are related to the exportation of liquefied petroleum gas, and FAQ 915, defines “liquefied petroleum gas” in line with the US Energy InformationOn the 2 Nov 2018 EO 13808 sanctions were expanded, under EO 13850, to include asses freezes and travel bans to whom ever fraudulently benefits from any specified government project or program.  On the 25 Jan 2019 the national emergency measures stated under EO 13692 were amended and extended under EO 13857. 

EU (CFSP) 2017/2074 introduces arms embargo, including the provision of financing or financial assistance related to military activities or equipment which might be used for internal repression, including in particular grants, loans and export credit insurance, as well as insurance and reinsurance, for any sale, supply, transfer or export of arms and related materiel or for the provision of related technical assistance, brokering services and other services directly or indirectly to any person, entity or body in, or for use in, Venezuela. This applies to contracts concluded after 13 Nov 2017. Also introduces a freezing of funds and economic resources for designated entities as listed in SDN list (updated periodically). UK SI 2017/1094 and SI 2018/108 implements EU sanctions. On the 6 Nov 2018 the EU renewed its sanctions under CFSP 2018/1656. All restrictive measure renewed under CFSP 2019/1889. Under (CFSP) 2020/1700 all restrictive measures were renewed for a further year until 14 November 2021. Pursuant of (CFSP) 2021/1965 and (EU) 2021/1959 all restrictive measure under CFSP 2020/1700, 2017/2063 and 2017/2074 were extended until 14 Nov 2022.
The Venezuela (Sanctions) (EU Exit) Regulations 2019 incorporates EU sanctions into UK law wef: 31 Dec 2020. 
This information has been collated by the International Underwriting Association of London and is intended as a guide only. The IUA does not accept any liability for the accuracy of this information.
This publication is intended to convey only general information about sanctions legislation and associated insurance coverage. It is not, and is not intended to be, a complete statement of the law relating to this area. It should not be relied on or be used as a substitute for legal advice in relation to any particular set of circumstances. Accordingly, IUA does not accept any liability for any loss which may arise from reliance on this information.