On November 17, 2020, the US Treasury Department’s Office of Foreign Asset Control (“OFAC”) amended General License (“GL”) 8F and re-issued it as General License 8G.  GL 8G extends the validity period of certain limited maintenance and wind-down transactions and activities involving Petróleos de Venezuela S.A. (“PdVSA”) until June 3, 2021.   Our blog posts describing previous amendments to the general license are available hereherehere, and here.

Specifically, GL 8G extends the validity period of the authorization for certain transactions and activities otherwise prohibited by Executive Order (“EO”) 13850 (as amended by EO 13857) or EO 13884 that are ordinarily incident and necessary to the limited maintenance of essential operations, contracts, or other agreements that are (i) for the safety or the preservation of assets in Venezuela, (ii) involve PdVSA or its 50%-or-more owned subsidiaries, and (iii) were in effect prior to July 26, 2019 for the following entities and their subsidiaries: Chevron Corporation; Halliburton; Schlumberger Limited; Baker Hughes; and Weatherford International (“Covered Entities”).  Importantly, GL 8G also extends the validity period of the authorization to wind-down PdVSA-related activities involving Covered Entities, effectively providing US companies an additional six months to exit the market.  The additional six months is likely a recognition by OFAC of the complexities in doing so.   Beyond the extension of the validity period, there were no further substantial changes to GL as there have been in previously amended versions. 

The authors acknowledge the assistance of Ryan Orange for this blog post.


Mr. Coward focuses on outbound trade compliance matters, including the extraterritorial application of US law, particularly US export control laws, anti-boycott regulations and trade sanctions/embargoes maintained by the US government against various countries. In addition, his practice covers issues of corporate conduct such as the application of the Foreign Corrupt Practices Act and foreign bribery laws. He provides international transactional advice; assistance in the design and implementation of corporate compliance programs, compliance audits, and internal investigations; and representation in enforcement proceedings.


Meg's practice involves assisting multinational companies with export compliance related matters, specifically trade sanctions and export control classifications. Additionally, she assists companies with respect to customs laws, anti-boycott laws and other trade regulation issues in the US and abroad. She also helps obtain authorizations from the US government for activities subject to sanctions regulations and US export control regulations, including the Export Administration Regulations and the International Traffic in Arms Regulations. Meg's practice extends to assistance in internal compliance reviews as well as enforcement actions and disclosures necessitated by US government action.