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 that were ordinarily incident and necessary to Chevon’s joint ventures in Venezuela involving PdVSA and PdVSA Related Entities (see our previous blog here). The amended GL 41A instead authorizes the wind-down of such transactions. These wind-down transactions are authorized until 12:01am ET on April 3, 2025. GL 41A also continues to exclude the following transactions from its scope:
- Payments of any taxes or royalties to the Government of Venezuela.
- Payment of any dividends, including a dividend in kind, to PdVSA, or any entity in which PdVSA owns, directly or indirectly, a 50% or greater interest.
- The sale of petroleum or petroleum products produced by or through the Chevron JVs for the exportation to any jurisdiction other than the United States.
- Any transaction involving an entity located in Venezuela that is owned or controlled by an entity located in the Russian Federation.
- Any transactions otherwise prohibited by the Venezuela Sanctions Regulations, including transactions involving any person blocked pursuant to the Venezuela Sanctions Regulations other than the blocked persons authorized under GL 41A or other OFAC authorizations.
