1099. Do non-U.S. persons risk exposure to U.S. sanctions for facilitating transactions related to Chevron Corporation (Chevron) and its joint ventures in Venezuela that are authorized pursuant to Venezuela General License (GL) 41?

No.  Non-U.S. persons, including foreign financial institutions, generally do not risk exposure to U.S. sanctions for facilitating transactions or payments for or on behalf of, directly or indirectly, Chevron, its subsidiaries, joint ventures, or contractors that are authorized pursuant to Venezuela GL 41.  Non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under the Venezuela Sanctions Regulations, 31 CFR Part 591, for engaging in transactions with blocked persons, where those transactions would not require a specific license if engaged in by a U.S. person.