1233. Do the dispute resolution requirements in certain Venezuela General Licenses (e.g., 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A) apply to all contracts associated with an authorized transaction?

No. The dispute resolution requirement in certain Venezuela General Licenses (GL), (e.g., 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A) only requires that contracts governing transactions with the Government of Venezuela (GOV) or certain other blocked persons (e.g., Petróleos de Venezuela, S.A. (PdVSA) in GL 52B or CVG Compañía General de Minería de Venezuela CA in GL 51C) specify that the dispute resolution proceedings relating to the contract occur in the United States, the United Kingdom, France, or Singapore. This requirement does not apply to indirect parties or indirect counterparties involved in transactions authorized by these GLs, such as downstream transactions involving the provision of shipping, insurance, or other services to an entity engaged in a transaction involving PdVSA. For example, this provision would not apply to a contract between an insurance provider and an established U.S. entity engaged in a transaction with PdVSA to purchase Venezuelan-origin oil (though it would apply to the contract between the U.S. entity and PdVSA).

Date Updated: August 27, 2026