On July 26, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended General License (“GL”) 8A and reissued it as GL 8B to extend it until October 25, 2019. GL 8B now has the same expiration date as GL 13B, which was also recently extended.

GL 8 was previously issued to authorize Chevron Corporation, Halliburton, Schlumberger Limited, Baker Hughes, and Weatherford International PLC to engage in transactions ordinarily incident and necessary to operations in Venezuela involving Petróleos de Venezuela SA or any entity in which it owns a 50 percent or greater interest (collectively, “PdVSA”) despite the latter’s SDN designation. GL 8B includes language limiting the scope of the authorization to transactions that are ordinarily incident and necessary to the maintenance of operations, contracts, or other agreements involving PdVSA that were in effect prior to July 26, 2019.

Please see our blog post on GL 8 here, GL8A here, and GL 13B here.

Author

Daniel Andreeff’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. His pro bono practice includes providing sanctions and export control advice to a global humanitarian NGO. * Admitted in New York only. Practice in the District of Columbia is under the supervision of a member of the District of Columbia Bar.

Author

Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.

Author

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.