Supplement to Special Maritime Newsletter on Payment in PETROS to the Venezuelan

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


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