Sanctions by the Numbers: Spotlight on Venezuela

Venezuela: Oil Production and Inflation, 2009–2020

Evolution of Sanctions on Venezuela

Following Maduro’s rise to power in 2013, U.S. sanctions strategy toward Venezuela evolved to address the ongoing deterioration of democracy and human rights in the country. From 2009 to 2015, the U.S. government issued fewer than five Venezuela-related sanctions per year, primarily related to drug-trafficking and providing financial support to Hezbollah. The major shift in U.S. sanctions policy toward Venezuela began in 2014 when Congress passed the Venezuela Defense of Human Rights and Civil Society Act. Following that, President Barack Obama signed Executive Order 13692 in March 2015, which highlighted human rights abuses associated with Maduro’s violent crackdown on protests. Most notably, this executive order created a country-specific sanctions program for Venezuela (VENEZUELA), which permitted targeted sanctions on individuals and entities involved in human rights abuses, anti-democratic practices, and public corruption, and ultimately changed the trajectory of U.S. sanctions on Venezuela. Under this new authority, the U.S. government sanctioned seven Venezuelan officials in the security forces for their involvement in suppressing protests, signifying a shift in U.S. sanctions policy and targets as democracy continued to deteriorate under Maduro.

New Venezuela-related Designations by Program, 2009–2021

The Trump administration dramatically broadened the range of Venezuelan targets under its “maximum pressure” campaign, imposing 46 designations on Venezuela within its first year, which was more than double the total (20) of all Obama-era sanctions on Venezuela. Following the continuing deterioration of Venezuelan democracy under Maduro in 2017, the Trump administration further intensified its use of existing sanctions programs against government officials, averaging 45 designations per year in 2017 and 2018. The Trump administration also implemented new sanctions authorities targeting Venezuela’s sovereign debt and access to the U.S. dollar to financially isolate Caracas from the world. This effectively restrained the Maduro regime’s ability to reconcile its sovereign debt as sanctions restricted its access to international financing.

U.S. sanctions continued to squeeze Venezuelan finances through a series of new executive orders which further barred transactions with the country. In August 2017, the Treasury prohibited transactions with the Venezuelan government and state-owned oil company Petróleos de Venezuela (PdVSA) within the American debt and equity financial markets with Executive Order 13808, which Executive Order 13835 later extended to the secondary market. This extension not only restricted the issuance of new external debt and repayment of debt coming due, but also put on hold a broader debt restructuring process as the United States sanctioned most government negotiators. In response, the Venezuelan government created a national cryptocurrency called the “petro” with purported backing from its oil, natural gas, and mineral reserves to circumvent U.S. sanctions in 2018. However, the Trump administration then issued Executive Order 13827 which banned all transactions using the petro, disincentivizing foreign entities and individuals from using this Venezuelan cryptocurrency market and stymieing Maduro’s efforts to financially engage with the international community through digital means. This demonstrated the global breadth of the United States’ sanctions toolkit and international financial dominance, as the possibility of losing access to the U.S. market by transacting in a sanctioned currency contributed to the already low global interest in adopting the petro. These measures made the Venezuelan government even more reliant on barter trade with Russia, and to a lesser extent China and Iran, ultimately pushing Caracas further into the orbit of traditional U.S. adversaries.

The Trump administration continued to impose heavy sanctions as Maduro refused to relinquish power and cease government-sponsored violence against civilians and protesters. In November 2018, the Trump administration created a new status-based sanctions program (VENEZUELA-EO13850), which grants the United States the ability to block assets of, and prohibit transactions with, actors operating in select sectors of the Venezuela economy or those involved in corrupt transactions with the Venezuelan government. Under Executive Order 13850 alone, the Treasury issued 148 designations in 2019 (80 percent of the annual total) on Venezuela. It initially targeted Venezuela’s gold sector and later expanded to the oil, financial, and defense and security industries throughout 2019 to sanction the major export sectors of the Venezuelan economy, including PdVSA and the Venezuelan Central Bank. The Trump administration expanded sanctions under Executive Order 13884, blocking the assets of the Venezuelan government and permitting sanctions on any individuals and entities who have materially assisted or supported the government of Venezuela. The sanctions on PdVSA were arguably one of the most impactful actions, given the country’s reliance on oil exports. In the wake of these sanctions, oil export revenue collapsed from $4.826 billion in 2018 to only $477 million in 2020. Meanwhile, sanctioning a country’s central bank adds another layer of difficulty in clearing foreign transactions, reinforcing the Trump administration’s goal of financially isolating Caracas from the rest of the world. The broad range of existing U.S. economic sanctions, along with concerns that sanctions could be further expanded to cover additional activity with Venezuela, has directly limited the ability of certain entities to engage with the country. This has resulted in widespread over-compliance from international financial institutions, banks, and aid organizations dealing with Venezuela, which has further isolated the country from the rest of the world.

Venezuela-related Designations by Category, 2009–2021

Although the sectoral sanctions mentioned above likely have had the greatest impact on Venezuela, the United States also took several other steps to curtail the country’s ability to evade sanctions. Most notably, the Treasury identified sanctions targeting Venezuela’s air transport and maritime industries as one way to reduce sanctions evasion tactics related to the export of oil and other sanctioned goods. While entities and individuals remain the most frequently sanctioned targets, the U.S. government also issued designations on aircraft (57) and vessels (68) to cut off Venezuelan oil exports, which are dependent on oil tankers typically operated by foreign shipping companies for transport. In an attempt to maximize sanctions pressure and economic coercive power, the U.S. government also pressured ship classification firms to withdraw the seaworthiness certifications of tankers sanctioned for operating in designated Venezuelan sectors, which would lead to a loss of insurance coverage, violation of contracts that require certification, and even rejection from ports. While these sanctions only apply to vessels involved in designated sectors, their collateral impact extends to all forms of trade as many shipping companies refuse to charter any vessel that has recently sailed to Venezuela due to the fear of engaging with a sanctioned target. In response, Venezuela has sought to evade U.S. sanctions by utilizing Iranian-owned tankers for illicit deliveries and transport of gasoline and oil. Since tankers owned by Iran’s National Iranian Tanker Company (NITC) have already been designated under Iran-related sanctions, there is little further action the United States can take in response beyond sanctioning the crews involved, which will likely fail to deter further sanctions evasion attempts.

Similar to vessels, sanctioning national aircraft can have significant impacts on a country’s ability to engage in international trade, travel, and other forms of commerce. For example, sanctioned aircraft can potentially lose their insurance and right to travel to the United States, as well as become difficult to sell abroad. In 2020, the Treasury Department sanctioned aircraft owned by PdVSA and sanctioned the Venezuelan state-owned flag carrier, Conviasa, along with its fleet of 40 planes, citing the use of the planes for political purposes by government officials. Members of the international community have criticized this action for punishing ordinary Venezuelans as it limits their ability to travel out of the country and the company’s access to necessary maintenance services abroad.

Venezuela-related Sanctions Outside of Venezuela, 2009–2021

As illicit financial activity benefiting the Maduro regime also occurs outside of Venezuela, U.S. sanctions extend beyond the country itself and to those around the world who materially support Caracas. For example, the Treasury has designated 147 (34 percent) out of the total 431 sanctions related to Venezuela on individuals and entities located in other countries, which demonstrates the breadth of Venezuela’s illicit networks and activity. The United States and Colombia are the most frequently sanctioned jurisdiction for Venezuela-related designations outside of Venezuela, mostly due to the large numbers of shell companies operating on behalf of Caracas in these countries. The Treasury has sanctioned 24 entities in the United States, mainly Venezuelan-owned shell companies in Florida and New York City, for their links to sanctioned Venezuelan individuals. Moreover, the Treasury named 18 of these sanctioned entities in its January 2019 designations on businessmen and Venezuelan government officials involved in a $2.4 billion foreign exchange network used to conceal the illicit ownership of luxury goods, aircraft, and yachts in violation of U.S. sanctions.

Venezuela has also utilized its networks in Colombia to conduct numerous money laundering schemes and financial crime. To date, the Treasury has levied 21 Colombia-related designations pursuant to Venezuela, all related to the activities of Colombian businessman Alex Nein Saab Moran (Alex Saab) and his extended international network linked to Venezuelan government officials and Maduro’s three step-children. The Treasury attributes to Saab the embezzlement of hundreds of millions of dollars from a food subsidy program on behalf of the Maduro regime, ultimately exploiting the country’s starving population. According to a July 2019 Treasury press release, Saab leveraged his sophisticated network of shell companies, business partners, and family members to launder funds around the world while attempting to evade U.S. sanctions.

Lastly, Panama (13), the Marshall Islands (10), and Liberia (10) have the next highest number of Venezuela-related designations due to maritime sanctions evasion schemes. Shipping is a major target for economic sanctions aimed at stymieing oil exports, and these countries often serve as flags of convenience for illicit maritime activity: a vessel owner can easily register their vessel under a foreign flag, such as Panama or the Marshall Islands, to profit from less restrictive regulations. Venezuela has a documented history of leveraging maritime obfuscation practices to evade U.S. economic sanctions which raises concerns of concerted Chinese and Russian efforts to help Caracas evade sanctions similar to the assistance they offer to North Korea.

The China and Russia Factor

Over the last four years, stringent U.S. sanctions have contributed to Venezuela’s increased dependency on traditional U.S. adversaries which presents major risks for sanctions evasions. Both China and Russia have sought ways to enhance their influence in Caracas through offering economic lifelines, advanced technology, and military training programs. In 2017, Caracas hired Chinese tech giant ZTE to create a new identification smart card to monitor and control citizen behavior under the auspices of a $70 million government effort that alleged to strengthen national security. ZTE also dispatched a special workers unit to join CANTV, Venezuela’s state-run telecommunications company, under the guise of offering managerial oversight and expertise. Although Beijing has reportedly reduced its financial support to Caracas over the years, it continues to violate U.S. sanctions to the benefit of the Maduro regime, as seen in the Treasury’s designation of the China National Electronics Import & Export Corporation (CEIEC). This designation exposed that the CEIEC supported CANTV’s anti-democratic efforts to restrict internet service and conduct cyber operations against political opponents, including digital surveillance.

Along with offering Venezuela economic lifelines and military contracts, Russia has also sought greater involvement in the country’s domestic affairs. In 2019, the Treasury designated Moscow-based bank Evrofinance Mosnarbank for aiding Venezuela in evading U.S. sanctions through financing the nation’s failed cryptocurrency, the petro. Overall, the Treasury has imposed four sanctions on Russian individuals and entities, and an additional two designations on Switzerland-based subsidiaries of Russia’s state-controlled Rosneft Oil Company for facilitating Venezuelan oil shipments. In addition to Russian-led sanctions evasions, the Treasury also imposed sanctions on four maritime firms and vessels illegally transporting Venezuelan oil to Cuba during the same year. However, increased designations have failed to dissuade Caracas from acknowledging foreign assistance in evading U.S. sanctions. In 2020, a day after Maduro illegitimately consolidated both political and legal power within the Venezuelan National Assembly, he convened with Russian officials on national Venezuelan television and thanked Russian President Vladimir Putin for his “interest and support for democracy in Venezuela,” adding, “Russia is an example of respect of cooperation.” Maduro’s swift acknowledgment of Russian support after illegitimately securing full power over Venezuela signals a likely continuation of joint Russian-Venezuelan efforts to evade U.S. sanctions on behalf of his regime. Despite financial liabilities, China and Russia will likely continue to support the Maduro regime as a strengthened alliance with Venezuela would grant both countries valuable geopolitical capital over the United States.

Biden and Caracas

While the overall review of the Venezuelan sanctions program is still underway, early signs suggest that the administration will continue to recognize Juan Guaidó as the interim president of Venezuela and the United States will likely keep many sanctions in place as it looks for ways to ease humanitarian issues. For example, in March 2021, the U.S. delegation to the World Trade Organization blocked Venezuela’s request to the panel seeking a review of U.S. sanctions on the grounds that the Venezuelan delegation was an illegitimate representative of the Venezuelan people. Although the Biden administration has not yet imposed any new sanctions on Venezuela, it also has not taken major steps to delist designated Venezuelan entities or individuals. The only notable delisting was of an Italian pizzeria owner in Verona, Italy, who was incorrectly sanctioned in January 2021 under the Trump administration due to a mistake in identity attribution. However, the Office of Foreign Assets Control has begun to provide certain humanitarian-related carve-outs in U.S. sanctions policy through a new general license which authorizes certain transactions with Venezuela related to the prevention, diagnosis, and treatment of COVID-19. Signed into effect on June 17, 2021, this serves as the Biden administration’s first major act to adjust sanctions toward the country in order to address COVID-19-related human suffering in Venezuela.

Under the Biden administration, U.S. sanctions on Venezuela will most likely remain relatively intact unless significant political change occurs in Venezuela. U.S. Secretary of State Antony Blinken vowed in early May 2021 that the United States will “continue to work with our partners across the region both to alleviate the suffering of the Venezuelan people and to exert pressure on the regime so the country can peacefully return to democracy.” This language suggests a continued hardline stance against the legitimacy of the Maduro regime but with perhaps greater collaborative efforts with allies and consideration of impacts of sanctions on the civilian population. The Biden administration has also signaled that foreign policy objectives should not come at the expense of efforts to address COVID-19 in heavily sanctioned countries such as Venezuela. For example, Secretary Blinken announced via Twitter that the United States will provide nearly $407 million in assistance to Venezuelans and host communities, signifying “longstanding U.S. leadership in alleviating the suffering of vulnerable people around the world in line with our values and interests as a nation.” Although the overall review of all U.S. sanctions programs is still underway, the Biden administration will most likely exert multilateral pressure with allies against the Maduro regime, including sustained sanctions, but with additional attention to humanitarian issues.

Methodology

Designations were drawn from the following sanctions programs: VENEZUELA, VENEZUELA-EO13850, VENEZUELA-EO13884, SDGT, SDNTK, IRAN, and IFSR. For the non-Venezuela-specific programs, only designations on Venezuelan individuals and entities or for those sanctioned for their involvement with Venezuela were counted.

Vessels and aircraft were categorized by the nationality of their registered owners.

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The CNAS Sanctions by the Numbers series offers comprehensive analysis and graphical visualization of major patterns, changes, and developments in U.S. sanctions policy and economic statecraft. Members of the CNAS Energy, Economics, and Security Program collect and analyze data from publicly available government sources, such as the Treasury Department’s Office of Foreign Assets Control.