On August 24, 2017, President Trump issued Executive Order 13808 (“E.O. 13808” or the “Executive Order”) titled “Imposing Additional Sanctions With Respect to the Situation in Venezuela.” The Executive Order prohibits certain transactions involving the Venezuelan Government, defined broadly to include Petroleos de Venezuela, S.A. (“PdVSA”), the Venezuelan state petroleum company, and any other entity owned or controlled by the Venezuelan Government. Given the explicit targeting of PdVSA, the new sanctions will have significant impact on the oil and gas industry. In a press release accompanying the issuance of the Executive Order, the White House indicated that the new prohibitions were “carefully calibrated to deny the Maduro dictatorship a critical source of financing to maintain its illegitimate rule.” Nevertheless, these sanctions represent a significant shift in the Administration’s approach to the ongoing situation in Venezuela. Before E.O. 13808, newsanctions related to Venezuela were limited to listing current and former government officials on the Specially Designated Nationals (“SDN”) List.

Below is a summary of the new prohibitions outlined in E.O. 13808, as well as the frequently asked questions (“FAQs”) and general licenses concurrently issued by the Office of Foreign Assets Control (“OFAC”), U.S. Department of the Treasury.