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Sanctions Related to Venezuela

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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…

On March 13, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) expanded the scope of three existing general licenses (“GLs”) and issued two amended Frequently Asked Questions (“FAQs”) related to certain imports and activities involving electricity and petrochemicals in Venezuela. On March 18, 2026, OFAC also issued a new GL authorizing transactions with Venezuelan state-owned Petróleos de Venezuela, S.A. (“PdVSA”), subject to certain conditions, and issued two new FAQs related thereto.…