Yes. Non-U.S. persons may engage in transactions or provide services that are ordinarily incident and necessary to the established U.S. entity’s transactions authorized by GL 46. Such activities or ancillary services could include: providing transportation and logistics services to an established U.S. entity for the export of Venezuelan-origin oil; providing marine insurance to vessels chartered by established U.S. entities to transport Venezuelan-origin oil; the financing of related cargoes or receivables; leasing storage facilities for Venezuelan-origin oil purchased by an established U.S. entity; or contracting with established U.S. entities for repair or maintenance services of infrastructure necessary to effectuate the export of oil from Venezuela, among others.
Please see FAQ 1235 for additional information regarding authorized downstream trading activities.
Please see FAQ 1231 for certain individuals and jurisdictions excluded from the scope of GL 46.