Although these actions targeted the export of Venezuelan oil, they would appear to point more broadly to heightened scrutiny being given to Venezuela by the U.S. administration’s highest echelons and Freehill’s note that “this makes the environment all the more unpredictable”.

It had been believed in the past that oil cabotage trades around Venezuela were probably of a low order of risk, but the accumulative tightening of sanctions over the past months has seemingly changed that dynamic. Accordingly, Freehill’s are now of the view that for cabotage and all Venezuelan oil trades generally:

“…we no longer assess risks for vessel owners as low or not high if the trade involves Venezuelan oil. Our present view is that any transaction involving Venezuelan oil is sanctionable unless specifically approved whether by specific license or otherwise. We think the cabotage trade…is fair game now.” [our emphasis]