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US Sanctions against Venezuela

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On May 1, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 42 (“GL 42”) under the Venezuela Sanctions Regulations (“VSR”), three new Venezuela-related Frequently Asked Questions (“FAQs”), and also amended one Venezuela-related FAQ. These developments occurred in the context of efforts by creditors to enforce judgments against Venezuela and appear to have been in response to a request from the Special Master for the US District…

On November 26, 2022, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued General License 41 (“GL 41“) authorizing Chevron Corporation (“Chevron”) to resume limited oil extraction operations in Venezuela and accompanying FAQs. According to the accompanying press release, OFAC issued GL 41 after Unitary Platform and President Maduro’s regime announced the resumption of negotiations; a humanitarian agreement focused on education, health, food security, flood response, and electricity programs that will…

On November 17, 2020, the US Treasury Department’s Office of Foreign Asset Control (“OFAC”) amended General License (“GL”) 8F and re-issued it as General License 8G.  GL 8G extends the validity period of certain limited maintenance and wind-down transactions and activities involving Petróleos de Venezuela S.A. (“PdVSA”) until June 3, 2021.   Our blog posts describing previous amendments to the general license are available here, here, here, and here. Specifically, GL 8G extends the validity period of the authorization…

On November 5, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Venezuela-related general license (General License No. 35) (“GL 35”) to authorize certain administrative transactions with the Government of Venezuela (“GOV”) prohibited by Executive Order (“EO”) 13884 (“Blocking Property of the Government of Venezuela”); issued General License No. 34A (“GL 34A”), which supersedes and replaces General License No. 34, and authorizes transactions involving certain GOV-related individuals prohibited by EO 13884; and identified five current GOV officials on the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to EO 13884.

Then, on November 21, 2019, OFAC announced the amendment of the Venezuela Sanctions Regulations (“VSR,” 31 C.F.R. Part 591) to incorporate additional EOs; make certain clarifying changes; add a GL authorizing US Government activities; and add an interpretive provision regarding activities related to judicial processes.  The VSR regulatory amendments took effect on November 22, 2019 concurrent with their publication in the Federal Register, available here.

These Venezuela sanctions developments are described in more detail below.  Our previous blog posts about US sanctions targeting Venezuela are available here.