Overview
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued multiple new and amended general licenses affecting a range of Venezuela‑related activities. This post provides a high-level summary of each authorization based on recently issued General Licenses 46B, 47, 48A, 49A, 50A, 51A, 52, 53, 54 and 55.
Energy and Petrochemical Sector Authorizations
- GL 46B authorizes transactions ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, and transportation of Venezuelan‑origin oil (including refining) and Venezuelan‑origin petrochemical products for importation into the United States by an established U.S. entity (as defined in the license). Following the license terms, contracts with the Government of Venezuela, PdVSA, or PdVSA entities must be governed by U.S. law and include U.S.-based dispute resolution, and any monetary payment to a blocked person