This circular provides information on the recent addition of the Maritime Authority of Venezuela (Instituto Nacional de los Espacios Acuaticos – “INEA”) to the US SDN list.
Since 2017, the US has imposed significant sanctions on companies and individuals in Venezuela, especially with regard to the oil industry. The Maritime Authority of Venezuela (INEA) has recently been added and included on the Specially Designated Nationals And Blocked Persons List (SDN). The inclusion was on that the basis that the company is said to be active in the oil sector of Venezuela by supporting the state oil company, Petróleos de Venezuela SA. The question arises whether the use of INEA services constitutes a breach of the sanctions. To clarify this, the American OFAC has now issued General License 30A in which this is further explained:
- Even before INEA was placed on the SDN list, it was the designated entity of the “Government of Venezuela” under EO 13884. As a result, US parties were already prohibited from trading with INEA without a license.
- The license requirement only applies to American individuals and companies. For non-US parties, the activities permitted under General License 30 A do not constitute a sanction violation.
- General License 30A stipulates that normal port charges, such as expenses for tugs and port charges, are in principle allowed unless they constitute a breach under EO 13850.
We advise members to take this into account when operating in Venezuelan ports. If you have any questions, please contact us at firstname.lastname@example.org.