Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela

This executive order declares a national emergency regarding Venezuela, blocking all property and interests in property of seven named individuals and any future persons determined by the Treasury Secretary to be responsible for undermining democratic institutions, human rights abuses, restricting freedoms, or public corruption in Venezuela. It also suspends entry into the United States of such persons, with limited exceptions for international obligations.

Federal Register Open PDF 80 FR 12747

Impact dates

Date TBD
Recurring and final reports to Congress on national emergency per NEA and IEEPA
Mar 9, 2015
Order effective at 12:01 a.m. eastern daylight time

Key directives

Block all property and interests in property of listed persons and future designees
Suspend entry of designated persons as immigrants or nonimmigrants
Prohibit donations to blocked persons
Prohibit transactions that evade or avoid order prohibitions
Authorize Treasury Secretary to promulgate implementing regulations
Authorize State Secretary to implement entry suspension
Authorize Treasury Secretary to remove persons from sanctions list
Submit recurring and final reports to Congress on national emergency

Who is ordered

Timeline

Immediate

Property blocking effective March 9, 2015 at 12:01 a.m. EDT
Seven named individuals in Annex subject to sanctions
Entry suspension takes effect

Near term (90d)

Treasury/State designation of additional persons under criteria
Implementation of regulations and licensing framework

Long term

Ongoing sanctions enforcement and compliance
Potential expansion of designated persons list
Congressional reporting on national emergency

Risks & tensions

Vague criteria for future designations ('complicit in,' 'materially assisted') create broad executive discretion
No prior notice requirement for listing raises due process concerns
Potential tension with international obligations regarding UN Headquarters Agreement
Broad definition of 'Government of Venezuela' including Central Bank could expand sanctions scope significantly
Impact on U.S. persons holding Venezuelan assets or doing business in Venezuela uncertain without specific licensing guidance