Venezuelan President Nicolas Maduro is evading U.S.-imposed sanctions by funneling cash from Venezuelan oil sales through a Russian state energy company, according to an April 18 report from Reuters. The cash flowing through Rosneft is the most recent sign of “the growing dependence of Venezuela’s cash-strapped government on Russia” as a result of U.S. sanctions, according to the report.
Russia export controls and sanctions
The use of export controls and sanctions on Russia has surged since the country's invasion of Crimea in 2014, and especially its invasion of Ukraine in in February 2022. Similar export controls and sanctions have been imposed by U.S. allies, including the EU, U.K. and Japan. The following is a listing of recent articles in Export Compliance Daily on export controls and sanctions imposed on Russia:
The European Union is imposing new antidumping duties on imports of urea and ammonium nitrate from the U.S., Russia, and Trinidad and Tobago, it said in a notice of its preliminary determination in the April 11 EU Official Journal. A provisional antidumping duty rate of 22.6% is now required on imports of the product by CF Industries Holdings, the sole U.S. exporter being investigated, as well as on urea and ammonium sulfate exported from the U.S. by all other companies. The new cash deposit rate takes effect April 11, though the EU may apply it retroactively as of March 22 (see 1903210046). That decision will be made at the final stage of the investigation.
In the April 11 edition of the Official Journal of the European Union the following trade-related notices were posted (see 1904120033 for notices from April 12):
The Trump administration is expected to complete a review of the current scope of U.S. export controls on countries subject to arms embargoes, including China, and may make potential regulatory changes by May 10, according to an April 5 blog post from Steptoe & Johnson. The administration’s review stems from a section of the 2018 Export Control Reform Act, which requires a “review relating to countries subject to comprehensive United States arms embargo.” The act specifically requires the Commerce, State and Defense departments, among others, to review export controls on trades with “military end uses and military end users,” according to the post.
The Treasury’s Office of Terrorism and Financial Intelligence is requesting a nearly $25 million budget increase from the previous year, partly to help with staffing concerns, according to Treasury’s annual budget report. OTFI lists its “increasing role” in the Trump administration as justification for the increased budget. The agency is requesting about $165 million.
The Trump administration is considering increasing sanctions pressure on Venezuela by imposing sanctions on companies from third countries that do business with President Nicolas Maduro and the Venezuelan regime, according to a March 29 report by Reuters. The potential move was announced by John Bolton, White House national security adviser, who told Reuters the administration is moving in the “direction” of secondary sanctions.
In the April 2 edition of the Official Journal of the European Union the following trade-related notices were posted:
In the March 21 edition of the Official Journal of the European Union the following trade-related notices were posted:
The Treasury’s Office of Foreign Assets Control’s recent action of sanctioning Evrofinance -- a Russian bank the U.S. suspects of working with the Venezuelan government -- was a two-part warning to Venezuela, the Kremlin and others, trade lawyer and former OFAC senior sanctions policy adviser Michael Dobson said in an interview. The U.S. will not hesitate to tighten restrictions on Venezuela, Dobson said, and it does not feel constrained to sanction “outside actors” assisting the Nicolas Maduro regime. The sanction (see 1903110014), announced in a March 11 OFAC notice, will be published in the March 22 Federal Register. Dobson, now a lawyer at Morrison Foerster, said he suspects Evrofinance of being a “very narrow vehicle” set up by Russia and Venezuela to facilitate trade and to “release some of the pressure from the Maduro regime's decreasing access to U.S. dollars.” The action will likely not become a trend for Venezuela, Dobson said, but a stand-alone action wherein the U.S. was able to enforce evasions of sanctions. “I think it’s just a warning,” Dobson said, adding that as long as U.S. companies aren’t doing business with Venezuela or Evrofinance, “I don't think this is going to have significant ripple effects.”
Exports of urea and ammonium nitrate from the U.S. to the European Union could eventually face antidumping and countervailing duty requirements as of March 22, after the EU published a notice the previous day directing member state customs authorities to “register” any of their imports of the product. In a procedure similar to “critical circumstances” in the U.S., EU authorities determined that U.S. exporters had been increasing exports after AD/CV duty investigations on urea and ammonium nitrate were launched in August 2018, in an effort to get in as much product as possible before duties take effect. As a result of the registration requirement, should the EU apply AD and CV duties in its final determination, any duties will be retroactive to the date the registration requirements began, i.e., March 22, 2019. The registration requirements also apply to Russia and Trinidad and Tobago.