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OFAC General License

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On June 30, 2025, the White House reissued National Security Presidential Memorandum-5 (“2025 NSPM-5”) focused on Cuba policy that it published in largely the same form in the first Trump Administration (see the “2017 NSPM-5”). As acknowledged in Section 4(a) of the reissued document, much of the contents of the 2025 NSPM-5 was already implemented in the first Trump Administration pursuant to the 2017 NSPM-5. Along with 2025 NSPM-5, the White House issued a related…

In less than two weeks, we have seen Syria go from one of the most heavily sanctioned countries on the planet to a country well on the road to establishing normal trade relations with the Western world. The latest flurry of developments started on May 13, 2025, when President Trump caught much of the world by surprise when he said in a speech in Riyadh: “I will be ordering the cessation of sanctions against Syria…

On March 24, 2025, the White House issued Executive Order 14245 (“EO 14245”) to implement potential tariffs for countries importing Venezuelan oil as well as a Fact Sheet that summarizes EO 14245 at a high level. On the same date, the US Treasury Department’s Office of Foreign Assets Control issued General License (“GL”) No. 41B extending the wind down period of certain transactions related to Chevron Corporation joint ventures (“JVs”) in Venezuela. EO 14245 This…

The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended Venezuela General License (“GL”) 41 to wind-down, rather than authorize, certain transactions related to the operation and management of Chevron Corporation’s joint venture with Petróleos de Venezuela, S.A. (“PdVSA”) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (“PdVSA Related Entities”). OFAC issued the original GL 41 on November 26, 2022, which authorized certain transactions…