U.S. Sanctions Update: New Sanctions Program Creates Risks For Companies Doing Business With Venezuela

On March 9, 2015, President Obama signed the Executive Order Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela, declaring the current situation in Venezuela a threat to national security and imposing sanctions on certain Venezuelan military and security officials. While the sanctions are limited to certain individuals for now, companies, both foreign and domestic, doing business in the region should ensure that their compliance programs capture the new sanctions to prevent possible violations. U.S. companies with business involving Venezuela should ensure that their activities do not relate to parties designated under the new sanctions. Non-U.S. companies engaged in business with or involving targeted parties face their own risks as sanctions may be imposed on persons or entities that provide material support to designated parties.