ELEMENTO LIMITED

Malta; Norway

35 Strait Street, Valletta, VLT 1434, Malta; 85 St. John Street, Valletta, MT-VLT1165, Malta; Norway

C 72520, Company Number; 920167667, Company Number

Elemento is based in Valletta, Malta, and has operated in the global oil sector since at least 2017. Elemento has purchased oil from PdVSA and then resold it to third-party customers on behalf of Bazzoni. Between July 2019 and July 2020, Elemento lifted and brokered the sale of at least five shipments of Venezuelan-origin crude oil supplied by PdVSA, several of which were coordinated directly with Libre Abordo or Swissoil. Elemento was designated today for operating in the oil sector of the Venezuelan economy and because it has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, PdVSA.

US

https://home.treasury.gov/news/press-releases/sm1239

2021-01-19

US

Executive Order 13850 Blocking Property of Additional Persons Contributing to the Situation in Venezuela

OFAC country specific

Venezuela

Blocking Property, Suspending Entry, Trade sanctions

• https://ofac.treasury.gov/faqs/topic/1581 • https://ofac.treasury.gov/media/932241/download?inline

On July 10, 2015, OFAC issued the Venezuela Sanctions Regulations, 31 CFR part 591 (the ‘‘Regulations’’) (80 FR 39676, July 10, 2015) to implement the Venezuela Defense of Human Rights and Civil Society Act of 2014 (Pub. L. 113– 278) and Executive Order 13692 of March 8, 2015 (‘‘Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela’’) (E.O. 13692). The Regulations were published in abbreviated form for the purpose of providing immediate guidance to the public. Since then, the President has issued six additional Executive orders pursuant to the national emergency declared in E.O. 13692: Executive Order 13808 of August 24, 2017 (‘‘Imposing Additional Sanctions With Respect to the Situation in Venezuela’’) (82 FR 41155, August 29, 2017); Executive Order 13827 of March 19, 2018 (‘‘Taking Additional Steps to Address the Situation in Venezuela’’) (83 FR 12469, March 21, 2018); Executive Order 13835 of May 21, 2018 (‘‘Prohibiting Certain Additional Transactions With Respect to Venezuela’’) (83 FR 24001, May 24, 2018); Executive Order 13850 of November 1, 2018 (‘‘Blocking Property of Additional Persons Contributing to the Situation in Venezuela’’) (83 FR 55243, November 2, 2018); Executive Order 13857 of January 25, 2019 (‘‘Taking Additional Steps To Address the National Emergency With Respect to Venezuela’’) (84 FR 509, January 30, 2019); and Executive Order 13884 of August 5, 2019 (‘‘Blocking Property of the Government of Venezuela’’) (84 FR 38843, August 7, 2019).

SDN