On January 29, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) revoked General License 43 (“GL 43”), which authorized certain transactions involving CVG Compania General de Mineria de Venezuela CA (“Minerven”). GL 43 was replaced with GL 43A to allow US Persons, through 12:01 a.m. eastern standard time, February 13, 2024, to wind down transactions involving Minerven (and entities it owns 50% or more) that were previously authorized by GL 43. After the wind-down period, US Persons are prohibited from engaging in virtually any dealings with Minerven or entities it owns 50% or more. This action was apparently prompted by what the US Government perceives as the failure by the Government of Venezuela (“GOV”) to fulfill its obligations under an electoral roadmap agreement with Venezuelan political opposition parties.
Furthermore, on January 30, 2024, the US Department of State (“State”) announced in a press release that renewal of GL 44, which provides certain relief to Venezuela’s oil and gas sector, is contingent upon progress in talks between GOV and the opposition parties, specifically regarding unrestricted participation of all presidential candidates in the 2024 election. In the press release, State was clear that failure to achieve this progress will result in GL 44 expiring on April 18, 2024. Both GL 43 and GL 44 were issued on October 18, 2023, in support of the Barbados Agreement signed between GOV representatives and the Unitary Platform in October 2024. Our previous blog post about the issuance of these two GLs can be found here.
On February 2, 2024, OFAC updated the Frequently Asked Questions (“FAQs”) that were originally issued on November 16, 2023 regarding the suspension of certain US sanctions against Venezuela on October 18, 2023. The updated FAQs provide that, following GL 43’s revocation, parties operating in the gold sector of the Venezuelan economy may be sanctioned by OFAC, pursuant to Executive Order 13850.
