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…
On January 29, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 46 (“GL 46”) authorizing transactions related to the exportation/reexportation of Venezuelan oil prohibited under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. Our blog posts about recent developments under US sanctions targeting Venezuela can be found here, here, here, and here. Subject to certain conditions, GL 46 authorizes all transactions involving the Government of Venezuela…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has amended two Russia-related General Licenses (“GLs”) —131A and 128B—affecting (i) contingent contract negotiations for acquisition of and maintaining/winding down transactions with certain Lukoil entities and (ii) retail transactions with ex-Russia Lukoil service stations. More information regarding each GL is below and our blog post regarding prior iterations of these GLs can be found here. Amended GL 131A On December 10, 2025, OFAC…
On November 14, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended two general licenses and issued two new general licenses (“GLs”)authorizing limited transactions involving Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) and entities in which they respectively own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively “Rosneft and Lukoil Entities”). Rosneft and Lukoil…