On March 6, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continued its trend of selectively easing the Venezuela sanctions by (1) issuing General License No. 51 (“GL 51”), the first general license (“GL”) beyond the energy sector, and (2) publishing six new Frequently Asked Questions (“FAQs”) addressing the scope of several of the previously issued energy-related GLs. In parallel, Venezuela has begun reforming its mining sector. Background Since late…
On March 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an updated FAQ 1238, providing guidance on whether OFAC would approve license applications authorizing the resale of Venezuelan‑origin oil for use in Cuba when consistent with the terms and conditions of Venezuela General License (“GL”) 46A (authorizing US entities to export, sell, deliver, etc. Venezuelan-origin oil). The FAQ is relevant for companies assessing potential transactions involving Venezuelan oil…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has amended two Russia-related General Licenses (“GLs”) – 55E and 115C – that authorize certain transactions related to crude oil originating from the Sakhalin-2 project and certain transactions with Russian entities related to civil nuclear energy. OFAC also updated several frequently asked questions (“FAQs”). Amended GLs 55E and 115C The amended GL 55E, “Authorizing Certain Services Related to Sakhalin-2,” authorizes, through 12:01 am…
On January 6, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 24 (“GL”), which authorizes certain transactions formerly prohibited by several US sanctions programs. OFAC also issued eight new Syria Frequently Asked Questions (“FAQs”) and amended one existing FAQ, as part of its effort to ease certain trading restrictions after rebel forces toppled Syrian President Bashar al-Assad’s regime on December 8, 2024. General License No. 24 This…