In the FCPAméricas Blog, Timothy O'Toole discusses the recent strained relations between Venezuela and the United States. Following a Venezuelan action expelling most U.S. Diplomats from the country, President Obama issued an Executive Order in response, which found that the current Venezuelan government has, among other things, engaged in "significant public corruption." There are seven high-level Venezuelan officials named in the Executive Order who have been blocked from their property and prevented from entering the United States. However, it is likely this list will grow as the U.S. Department of the Treasury, in conjunction with the Office of Foreign Asset Control, begins a review of other individuals who qualify for additional sanctions, O'Toole said.
As the imposition of sanctions continues, O'Toole offers a number of suggestions for companies aiming to do business in Venezuela. "First, companies must carefully review these sanctions in light of their business in Venezuela to ensure they are not engaging in improper transactions with sanctioned individuals. Second, companies doing business in Venezuela should begin to carefully monitor further actions on this issue by the U.S. Department of the Treasury because, as the sanctions order makes clear, this is just the first step of what will likely be a growing Venezuelan sanctions regime," O'Toole said.