pdvsa
Navigating Complex Sanctions for State Owned Oil Companies
situation
Monómeros Colombo Venezolanos, S.A., a leading petrochemical company affiliated with the state-owned Petróleos de Venezuela (PDVSA),
found itself amidst stringent U.S. sanctions. The company, recognized for its significant contributions to the agro-industrial sector and social
responsibility, was directly impacted by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designation of PDVSA
under Executive Order (E.O.) 13850 in January 2019. This action placed Monómeros and its operations under severe restrictions due to its
majority ownership by entities directly tied to PDVSA.
task
GSI was entrusted with the critical task of facilitating and procuring the extension/renewal of OFAC License No. EO13850-2019-360364-5 for
Monómeros. This required a multifaceted legal and strategic approach to navigate the intricate web of sanctions and opposition efforts,
aiming to secure the company's ability to continue its operations and contribute to the agro-industrial sector in Colombia and beyond.
actions
To address this complex challenge, GSI implemented a comprehensive strategy encompassing several key activities:
1
Legal and Strategic Petition Filing: GSI filed voluminous petitions on behalf of Monómeros, meticulously outlining the legal basis for the license renewal and countering any disinformation efforts by opposition forces in Venezuela.
2
Informational Campaigns: Efforts were made to correct narratives and inform U.S. policymakers of the critical role
Monómeros plays in the agricultural sector and its alignment with U.S. interests, despite its indirect association with
sanctioned entities.
3
Counteraction of Opposition: GSI actively countered the hostile actions and narratives promoted by opposition forces,
including those led by prominent figures and the Guaidó government in Venezuela, ensuring that Monómeros' perspectiv
was accurately represented.
4
Legal Representation and FARA Compliance: GSI ensured all necessary Foreign Agents Registration Act (FARA)
registrations, approvals, and filings were in place, including for a former U.S. Ambassador enlisted to assist in the OFAC
license procurement process.
results
Despite facing significant opposition and the potential risk of not securing the license renewal, GSI's strategic and legal efforts resulted in
the successful procurement of the OFAC license extension for Monómeros Colombo Venezolanos, S.A. The renewal allowed the company to
maintain all rights and operational capabilities as per the previous licenses, with no additional limitations imposed despite the opposition's
efforts.
This accomplishment not only secured Monómeros' ability to continue its vital contributions to the agro-industrial sector but also
demonstrated GSI's adeptness in navigating the complexities of international sanctions and regulatory challenges. Monómeros can now
focus on its mission of producing and distributing essential products for agriculture and industry, reinforcing its commitment to social
responsibility and market leadership in Colombia and beyond.