As a part of the sanctions imposed against the Maduro-led Venezuelan government, the United
States prohibits transactions involving Petros and any other crypto-currency being promoted by
Venezuela. Executive Order 13827, «Taking Additional Steps to Address the Situation in
Venezuela,» dated March 19, 2018, states: «All transactions related to, provision of financing for,
and other dealings in, by a United States person or within the United States, any digital currency,
digital coin, or digital token, that was issued by, for, or on behalf of the Government of Venezuela
on or after January 9, 2018, are prohibited as of [March 19, 2018].” OFAC FAQ No. 564 states,
the «petro»» and «petro-gold» are considered «digital currency, digital coin, or digital token» for
purposes of the EO 13827 prohibition.
Therefore, any U.S. person or any person within or subject to the jurisdiction of the United
States engaging or dealing in Petro-denominated transactions with the Venezuelan Maritime
Authority (“INEA” for its acronym in Spanish) would risk violating OFAC sanctions. OFAC has also
stressed that sanctions compliance obligations are the same for U.S. Persons (or those otherwise
subject to OFAC jurisdiction), regardless of whether they transact in digital denominated
currency or traditional fiat currency, and have issued detailed FAQ addressing such digital
currency risks and obligations (such as FAQ Nos. 559-560).
Non-U.S. Persons and entities considering whether to engage in such Venezuela-related
transactions should consider the potential risk that the U.S. may designate non-U.S. persons or
entities as SDNs or blocked persons or entities under the Venezuela sanctions regime.
If you require further information about payments for services to INEA, or any other Venezuelan
entity such as the Port Authority or the National Institute of Canals, in Petros, or sanctions
against Venezuela, please contact Aurelio.Fernandez-Concheso@clydeco.com.ve and/or