Page 14: of Marine News Magazine (March 2026)

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Washington Watch

U.S.-Venezula Relations

The Impact of U.S.-Venezuela

Relations on Ocean Shipping

By J. Philip Nester, Partner, Benesch Law while the U.S. Department of Treasury’s Of? ce of Foreign

U.S.–Venezuela relations

Assets Control (“OFAC”) has issued general licenses permit- have entered a consequential phase for ocean transporta- ting limited diluent exports and controlled oil-sector activi- tion, energy markets, and trade compliance. Sanctions tar- ty. Licensed trade now coexists with aggressive enforcement, geting Venezuela’s oil sector and maritime networks now as regulators and insurers assess compliance through vessel combine escalated enforcement, including tanker seizures, movements, chartering structures, and operational records.

vessel interdictions, and intensi? ed scrutiny of shipping Regulators are closely monitoring tanker movements, structures, with narrowly-tailored licenses permitting spe- ship-to-ship transfers, ownership and chartering arrange- ci? c oil exports, diluent shipments, and related maritime ments, accounting information systems (“AIS”) and practic- services. This has blurred traditional lines between opera- es, as well as risk-transfer structures that are common in the tional risk, trade compliance, and risk transfer strategies. tanker and bulk trades. Operational decisions such as slot

Commercial decisions affecting counterparties, charters, charters, pooling arrangements, feeder services, counterpar- routing, documentation, and payments carry a heightened ty onboarding, AIS management, and documentation sup- potential for sanctions violations, particularly if commu- port are being scrutinized for “facilitation” if services have a nications or shipment records have a Venezuelan nexus. Venezuelan connection. Reliance on contractual terms and

Stakeholders procuring or providing ocean services must counterparty risk-allocation provides limited protection if treat maritime operations, sanctions compliance, and risk voyage logs, emails, or compliance reviews demonstrate that management as an integrated analysis. commercial teams do not work within those parameters to avoid sanctions risk. These documents are scrutinized not only by regulators, but also insurers, P&I Clubs, and lend-

Ocean Transportation Sanctions Risk

U.S. actions targeting the Venezuelan oil sector have ers evaluating exposure, defenses, and ongoing support.

reshaped the risk pro? le for providers and users of ocean

Underwriting Shifts and Commercial De-Risking transportation and logistics services, including chartering, pooling, and maritime supply chains. Enforcement has ex- Sanctions exposure in Venezuela-linked trade is insep- panded beyond civil penalties to include tanker seizures, na- arable from risk transfer strategies, particularly for older val interdictions, and sustained scrutiny of “shadow ? eets,” tankers tied to Venezuelan crude operating in a “shadow © mrnai/AdobeStock 14 | MN March 2026