On May 12, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced the lifting of US sanctions on Nynas AB (“Nynas”) and the related revocation of General License No. 13E (“Authorizing Certain Activities Involving Nynas AB”) (“GL 13E”). We blogged about last month’s extension of GL 13E here. Nynas and its subsidiaries were previously subject to US sanctions because Nynas was indirectly owned and controlled by PetrĂłleos de Venezuela SA (“PdVSA”) and,…
On May 1, 2020, the Trump Administration issued Executive Order 13920 on “Securing the United States Bulk-Power System” (“Bulk-Power System EO”), which aims to prevent “foreign adversaries” from exploiting vulnerabilities in the US bulk-power system in furtherance of US national security. As explained in further detail in the press release concurrently published by the Department of Energy, the Bulk-Power System EO is meant to prohibit certain transactions involving bulk-power system equipment where the Secretary of…
On April 21, 2020, the US Treasury Departmentâs Office of Foreign Assets Control (âOFACâ) amended General License (âGLâ) 8E and re-issued it as General Licence No. 8F. GL 8F extends the validity period of certain maintenance activities involving PetrĂłleos de Venezuela S.A. (âPdVSAâ) until December 1, 2020, but also narrows the scope of the prior license and provides a new authorization for âwind-downâ transactions and activities. Our blog posts describing previous amendments to the general license…
On March 31, 2020, the US Government issued a proposed framework for a peaceful democratic transition in Venezuela. The framework outlines 13 steps for a restructured Government of Venezuela (“GOV”) that, if followed, would lead to the lifting of US sanctions on the GOV, PetrĂłleos de Venezuela, S.A. (“PdVSA”), and other GOV officials and agencies. The framework provides a total of 13 actions, including, among others: a full return of, and restoration of all powers…