http://settysoutham.wordpress.com/2011/05/24/and-the-sanctions-are-pdvsa-vc/
 May 24, 2011 · 11:24 am
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And the sanctions are… (PDVSA.ve) (Updated)

The US Secretary of State decided to impose the following sanctions on
Venezuela’s state oil company PDVSA in response to shipments of fuel to
Iran, according to a US government official briefed on the matter. These are
the mandatory sanctions required by the US law that imposed sanctions on
Iran in an effort to get Iran to halt any possible nuclear weapons program.
The sanctions imposed on PDVSA (not on Venezuela’s government, mind you)
are:

- A prohibition on US government procurement contracts (just PDVSA, not
subsidiaries such as Citgo)

- A ban on new export licenses (existing licenses will be respected)

- A ban on Export Import (Exim) Bank financing (not very important, as Exim
Bank stopped lending to Venezuela before the PDVSA strike and lockout in
2003)

Basically, weak sanctions. But still, US sanctions on Venezuela. Expect
fireworks.

UPDATE: The Associated Press
version<http://www.washingtonpost.com/politics/us-officials-7-foreign-countries-being-sanctioned-in-connection-with-iranian-nuclear-issue/2011/05/24/AFCFfTAH_story.html>
.

 Sanctions on PDVSA? RLY? (updated second time)

So says 
Reuters<http://af.reuters.com/article/energyOilNews/idAFWAT01513120110524>
:

WASHINGTON May 24 (Reuters) – The United States will sanction Venezuela’s
state oil company PDVSA on Tuesday for dealing with Iran in violation of a
U.S. ban on such trade, sources briefed on the matter told Reuters.

(Hat tip to the
Devil<http://devilsexcrement.com/2011/05/24/us-to-sanction-pdvsa-and-six-other-firms-for-dealings-with-iran/>
)

Quoting from my earlier coverage of this
topic<http://settysoutham.wordpress.com/2011/02/24/pdvsa-iran-fuel-sales-sanctions/>
:

Venezuela’s on-again, off-again approach to fuel sales to Iran has become
more intriguing in recent weeks, since Reuters published a
story<http://www.forexyard.com/en/news/Venezuelas-PDVSA-sends-gasoline-to-Iran-trade-2011-01-31T133546Z-UPDATE-1>saying
that Venezuela had shipped two cargoes of fuel. It would be of purely
passing interest except that the U.S. strengthened its
sanctions<http://fpc.state.gov/documents/organization/156527.pdf>(PDF)
on Iran last year to punish companies that provide fuel to the
country, as a way of pressuring the Islamic Republic to be more servile
about proving it has no nuclear weapons-related program activities.

This makes it explosive that there are supposedly documents proving a sale
of reformate from PDVSA to Iran. Josh Shahryar posted three
documents<http://pajamasmedia.com/blog/pjm-exclusive-chavez-caught-red-handed-sending-gasoline-to-iran/>purporting
to show that the shipments happened. As for describing his
sources, he said only “Documents obtained by credible sources close to the
matter.”

PDVSA President Rafael Ramirez has repeatedly denied such sales in recent
months (news reports from
October<http://www.reuters.com/article/2010/10/28/businesspro-us-venezuela-oil-idUSTRE69R0DX20101028>and
February <http://www.msnbc.msn.com/id/41430734/ns/business-oil_and_energy/>),
and a PDVSA spokesman, who requested not to be named citing company policy,
referred me to Ramirez’s remarks in response to the Pajamas Media article. I
sent him links to the documents and am awaiting a reply about whether the
company can confirm their veracity.

A U.S. State Department brochure on Iran sanctions (sorry, no link as my
source requested that the document not be distributed in full) says the
executive branch has little discretion when it comes to companies known to
have violated the law. It’s not like some foreign policy items, like
deciding whether a country is cooperative against terrorism or drugs, where
judgment can play a role. If a country ships fuel to Iran, sanctions click
in:

Iran Sanctions Act … requires the President to impose sanctions on a wide
variety of activities in Iran’s energy sector. Activities that can trigger
sanctions include … Selling or providing Iran with refined petroleum
products, with
- Fair market value of $1 million or more; or
- Aggregate fair market value of $5 million or more in a 12-month period

And the sanctions are:

Three or more out of nine possible sanctions shall be imposed on any person
determined to have engaged in sanctionable activities. The nine sanctions
would prohibit:
1. Export assistance from the Export-Import Bank of the United States;
2. Licenses for exports;
3. Private U.S. bank loans exceeding $10 million in any 12-month period;
4. If the sanctioned person is a financial institution, designation as a
primary dealer in USG debt instruments or services as a repository of USG
funds;
5. Procurement contracts with the United States Government;
6. Foreign exchange transactions subject to U.S. jurisdiction;
7. Financial transactions subject to U.S. jurisdiction;
8. Transactions with respect to property subject to U.S. jurisdiction;
9. Imports to the United States from the sanctioned entity.

Under this law, it would be possible to hit PDVSA hard by applying sanctions
7, 8, and 9, or to hit it in an almost insignificant way, with measures 1, 2
and 5, for example. Regardless, sanctions is sanctions.

CONTINUES 
HERE<http://settysoutham.wordpress.com/2011/02/24/pdvsa-iran-fuel-sales-sanctions/>
  Will PDVSA be sanctioned for Iran fuel sales?

*Ending updated*

Venezuela’s on-again, off-again approach to fuel sales to Iran has become
more intriguing in recent weeks, since Reuters published a
story<http://www.forexyard.com/en/news/Venezuelas-PDVSA-sends-gasoline-to-Iran-trade-2011-01-31T133546Z-UPDATE-1>saying
that Venezuela had shipped two cargoes of fuel. It would be of purely
passing interest except that the U.S. strengthened its
sanctions<http://fpc.state.gov/documents/organization/156527.pdf>(PDF)
on Iran last year to punish companies that provide fuel to the
country, as a way of pressuring the Islamic Republic to be more servile
about proving it has no nuclear weapons-related program activities.

This makes it explosive that there are supposedly documents proving a sale
of reformate from PDVSA to Iran. Josh Shahryar posted three
documents<http://pajamasmedia.com/blog/pjm-exclusive-chavez-caught-red-handed-sending-gasoline-to-iran/>purporting
to show that the shipments happened. As for describing his
sources, he said only “Documents obtained by credible sources close to the
matter.”

PDVSA President Rafael Ramirez has repeatedly denied such sales in recent
months (news reports from
October<http://www.reuters.com/article/2010/10/28/businesspro-us-venezuela-oil-idUSTRE69R0DX20101028>and
February <http://www.msnbc.msn.com/id/41430734/ns/business-oil_and_energy/>),
and a PDVSA spokesman, who requested not to be named citing company policy,
referred me to Ramirez’s remarks in response to the Pajamas Media article. I
sent him links to the documents and am awaiting a reply about whether the
company can confirm their veracity.

A U.S. State Department brochure on Iran sanctions (sorry, no link as my
source requested that the document not be distributed in full) says the
executive branch has little discretion when it comes to companies known to
have violated the law. It’s not like some foreign policy items, like
deciding whether a country is cooperative against terrorism or drugs, where
judgment can play a role. If a country ships fuel to Iran, sanctions click
in:

Iran Sanctions Act … requires the President to impose sanctions on a wide
variety of activities in Iran’s energy sector. Activities that can trigger
sanctions include … Selling or providing Iran with refined petroleum
products, with
- Fair market value of $1 million or more; or
- Aggregate fair market value of $5 million or more in a 12-month period

And the sanctions are:

Three or more out of nine possible sanctions shall be imposed on any person
determined to have engaged in sanctionable activities. The nine sanctions
would prohibit:
1. Export assistance from the Export-Import Bank of the United States;
2. Licenses for exports;
3. Private U.S. bank loans exceeding $10 million in any 12-month period;
4. If the sanctioned person is a financial institution, designation as a
primary dealer in USG debt instruments or services as a repository of USG
funds;
5. Procurement contracts with the United States Government;
6. Foreign exchange transactions subject to U.S. jurisdiction;
7. Financial transactions subject to U.S. jurisdiction;
8. Transactions with respect to property subject to U.S. jurisdiction;
9. Imports to the United States from the sanctioned entity.

Under this law, it would be possible to hit PDVSA hard by applying sanctions
7, 8, and 9, or to hit it in an almost insignificant way, with measures 1, 2
and 5, for example. Regardless, sanctions is sanctions.

Shipping companies and their insurers can also be sanctioned for being
involved in Iran trade, according to a separate State Department brochure.

As far as the supposed PDVSA documents’ credibility, I sent the link to a
reporter who covered Venezuela oil for years and that person said it was
“real stuff.” I also sent it to a trader who said that while it’s hard to
say if the documents are real, the vessel is real “and appears to have been
in Jebel Ali in Dubai in
January.<http://www.marinetraffic.com/ais/shipdetails.aspx?MMSI=314340000>”
It would be really nice to know a bit more about the source of these
documents and why Sharyar considers the “sources” credible.

If the documents are real, a very interesting game starts to play out — U.S.
leaders, looking at Cuba, for example, must know that sanctions can
strengthen a target regime. Does the U.S. want to be the main issue in the
next Venezuelan election? Who would benefit?

Direct links to Sharyar’s documents:
<http://settysoutham.files.wordpress.com/2011/02/1-15.jpg><http://settysoutham.files.wordpress.com/2011/02/1-32.jpg><http://settysoutham.files.wordpress.com/2011/02/1-41.jpg>

*Update:* It occurs to me that I should emphasize that I am skeptical of
these documents. I have no evidence of forgery but in a situation like this,
I wouldn’t be surprised to find out that they were fake. So please be
cautious in dealing with this situation, at least until someone who has
actually seen a PDVSA fuel shipping receipt confirms that the basics of
these documents match up with reality — that the form has the right codes,
the person named still works at PDVSA, etc. The Curacao document is awful
blurry — I’m sure someone physically on the island can get a better copy if
it’s real.


[Non-text portions of this message have been removed]



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