The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity… Read more
As a general matter, U.S. sanctions under E.O. 14404 are not focused on disrupting the delivery of food, medicine, or medical devices to Cuba. The U.S. government does not intend to target non-U.S. persons under E.O. 14404 for engaging in transactions related to the provision, directly or… Read more
Yes. OFAC's designation of Nobitex, Wallex, Bitpin, Ramzinex, Aban Tether, or any digital asset exchange pursuant to Executive Order (E.O.) 13902 for operating in the Iranian financial sector means that foreign financial institutions and other non-U.S. persons who transact with these exchanges may… Read more
OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries ("LIG Entities"): GL 128C and GL 131I . The GLs are similar but have different expiration dates and terms as each serves a different purpose. To mitigate the… Read more
On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia's energy sector and degrade Russia's ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-… Read more
The U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater… Read more
GL 61 authorizes transactions ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the installation, maintenance, refurbishment, repair, upgrade, operation, or support of telecommunications in Venezuela,… Read more
Specific license applications to perform any contingent contracts executed pursuant to GL 49 will be assessed on a case-by-case basis consistent with U.S. foreign policy and national security priorities. Recent Venezuela-related general licenses issued by OFAC have included various limitations in… Read more
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.… Read more
Yes. Certain Venezuela general licenses (GLs), including 46D , 47B , 48B , 50C , 51C , 52B , 54B , and 61A , require that any contract for authorized transactions with the Government of Venezuela or certain other blocked persons (e.g., Petróleos de Venezuela, S.A. in GL 52B or CVG Compañía General… Read more