Since August 21, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has made a series of changes to the Venezuela-related general licenses (“GLs”) issued under the Venezuela Sanctions Regulations, 31 CFR part 591 (“VSR”). OFAC removed the US governing-law condition from the GLs that included it and updated the associated Frequently Asked Questions (“FAQs”). It issued two new GLs, (General License No. 61 (“GL 61”), since replaced by GL 61A,…
On July 27, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a statement (here) of enforcement policy committing not to take supervisory or enforcement action against US financial institutions under the Bank Secrecy Act (“BSA”) in connection with the provision of authorized financial services provided in Venezuela. The statement was issued in consultation with the Internal Revenue Service and the staffs of the Board of Governors of the Federal Reserve…
On June 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three Venezuela-related general licenses and amended FAQ 595. The most notable development is new General License 59 (“GL 59”), which authorizes certain aircraft safety-related activities for Venezuelan Specially Designated National airline, Conviasa. OFAC also reissued its telecommunications and mail authorization as General License 24A (“GL 24A”), again delayed the effectiveness of the PdVSA 2020 bond authorization through General…
On June 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a suite of updated Venezuela-related general licenses (“GLs”) that slightly ease certain licensing conditions related to governing law and dispute resolution clauses in contracts involving the Government of Venezuela, Petróleos de Venezuela S.A. (“PdVSA”), CVG Compañía General de Minería de Venezuela CA (“Minerven”), or any entity in which PdVSA or Minerven owns, directly or indirectly, a 50% or…