President Donald J. Trump issued an Executive Order (“E.O”) prohibiting certain financial transactions with the government of Venezuela. President Trump cited the Maduro regime’s recent activities, which include “attempts to undermine democratic order by holding snap elections that are neither free nor fair” – a reference to the presidential elections held on May 20.
The transactions prohibited by the E.O. include, among others, any dealings in the United States or by U.S. persons related to:
- the purchase of debt owed to the Government of Venezuela, including accounts receivable;
- debt owed to the Government of Venezuela that, after the effective date of the E.O., is pledged as collateral, including accounts receivable; and
- the sale, transfer, assignment or pledging as collateral by the Government of Venezuela of any equity interest in which the Government of Venezuela has 50 percent or greater ownership interest.
As with previous Venezuela-related Orders, including E.O. 13692, E.O. 13808 and E.O. 13827, the “Government of Venezuela” is defined broadly to cover not only political subdivisions and agencies, but also companies and other entities – including the state-owned oil company Petroleos de Venezuela S.A. (“PdVSA”) – that are owned or controlled by, or acting for or on behalf of, the Government of Venezuela.