Introduction The current geopolitical environment in Venezuela is continuing to evolve. While the legal and business environment has improved, businesses operating or looking to operate there are still continuing to analyze risks. At the same time, tangible steps are being taken to better position Venezuelan industries for foreign investment, including a recent partial reform of Venezuela’s Organic Hydrocarbons Law. On the US front, sanctions remain in place against the Venezuelan government and Specially Designated Nationals…
This week, the US relaxation of sanctions against Venezuela’s oil and gas sector entered a new phase with the publication of a general license authorizing a broad range of upstream oil and gas activities. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has been busy with Venezuela-related actions over the past few weeks. We previously blogged about general licenses authorizing oil trading and downstream activities (blog post here) and the…
On January 29, 2026, President Trump signed Executive Order 14380, “Addressing Threats To the United States by the Government of Cuba” (the “Executive Order”), in which he declared a national emergency with respect to Cuba and authorized the United States to impose new tariffs on imports from countries that directly or indirectly supply oil to the Government of Cuba. The Executive Order is accompanied by a White House Fact Sheet outlining the administration’s national security…
On February 2, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued General License 5U, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 20, 2026,” to again delay the effective date of this authorization to March 20, 2026. This development is not related to recent developments in US sanctions targeting Venezuela, which we recently blogged about here. GL 5U authorizes…