No. E.O. 13808, as amended by E.O. 13857, does not authorize the blocking of property. E.O. 13808, however, should be read in conjunction with other Venezuela-related authorities, such as the E.O. 13884, which blocks the Government of Venezuela, and E.O. 13850, as amended, under which certain Government of Venezuela entities, including Petróleos de Venezuela, S.A. (PdVSA), are designated.
Subsection 1(a)(i) of E.O. 13808 prohibits engaging in transactions related to, providing financing for, or otherwise dealing in debt issued on or after August 25, 2017, with a maturity of longer than 90 days and issued by, on behalf of, or for the benefit of PdVSA, its property, or its interests in property.
Subsection 1(a)(ii) of E.O. 13808 prohibits engaging in transactions related to, providing financing for, or otherwise dealing in debt issued on or after August 25, 2017, with a maturity of longer than 30 days and issued by, on behalf of, or for the benefit of any other segment of the Government of Venezuela, its property, or its interests in property. That subsection further prohibits engaging in transactions related to, providing financing for, or otherwise dealing in equity issued on or after August 25, 2017, and issued by, on behalf of, or for the benefit of the Government of Venezuela (including PdVSA), its property, or its interests in property.
Subsection 1(a)(iii) of E.O. 13808 prohibits engaging in transactions related to, providing financing for, or otherwise dealing in bonds issued by the Government of Venezuela prior to August 25, 2017.
Subsection 1(a)(iv) of E.O. 13808 prohibits engaging in transactions related to, providing financing for, or otherwise dealing in dividend payments or other distributions of profits to the Government of Venezuela by any entity owned or controlled, directly or indirectly, by the Government of Venezuela.
Section 1(b) of E.O. 13808 prohibits purchasing any securities from the Government of Venezuela other than securities issued on or after August 25, 2017, with a maturity of less than or equal to 90 days (for PdVSA) or 30 days (for the rest of the Government of Venezuela).
E.O. 13808 prohibits transactions by U.S. persons wherever they are located, and transactions within the United States. For transactions involving blocked persons, including the Government of Venezuela and any entity in which it owns, directly or indirectly, a 50 percent or greater interest, U.S. persons are prohibited from engaging in any activity or transaction with such blocked persons unless exempt or otherwise authorized by OFAC. If there is a Venezuela-related general license authorizing dealings with such blocked persons, but the transactions or dealings fall within the prohibitions of E.O. 13808, U.S. persons should reject such transactions, unless an authorization allowing transactions and other dealings otherwise prohibited by E.O. 13808 also applies. U.S. persons must report to OFAC any blocked or rejected transactions within 10 business days.