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Sanctions Targeting Venezuela

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On October 18, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) implemented limited sanctions relief under the Venezuela Sanctions Regulations (the “VSR”) to the Government of Venezuela (the “GOV”) and certain sectors of the Venezuelan economy in response to the signing of an electoral roadmap agreement between GOV representatives and Venezuelan political opposition parties. OFAC and the State Department have made clear that additional sanctions relief and the continuance of…

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 December 23, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (“EAR”) by adding a new “Military End User List” (“MEU List”) as supplement no. 7 to part 744 of the EAR. The final rule adds 102 entities to the MEU List, which will consist of Chinese, Russian, and Venezuelan entities that the US Government has determined are “military end users” for purposes…