While E.O. 13884 blocks all property and interests in property of the Government of Venezuela that come into the possession or control of U.S. persons or U.S. jurisdiction, the Venezuelan people are not subject to comprehensive U.S. sanctions. Sanctions do not preclude U.S. persons from exporting… Read more
No, as long as your transaction or other dealing does not involve property or interests in property of a Specially Designated National. That said, you should make sure that your proposed export is authorized by the U.S. Department of Commerce, Bureau of Industry and Security ("BIS") , which… Read more
Yes. General License 4 authorizes all financing and other dealings in new debt related to the exportation or reexportation of agricultural commodities, medicine, medical devices, components, or replacement parts for medical devices, to Venezuela, or to persons in third countries purchasing… Read more
In the Lima Declaration of August 8, 2017, 12 countries across the Americas refused to recognize the Constituent Assembly or the laws it adopts because of its illegitimate nature, while at the same time fully backing the democratically elected IV Venezuelan National Assembly seated on January 5,… Read more
OFAC intentionally excluded the Venezuela Government International Bond issued on December 29, 2016 (ISIN USP97475AQ39, CUSIP AM1108092) (“the 2036 bond”) from the Annex to General License 3 because available information indicates that the Government of Venezuela is both the bond’s issuer and sole… Read more
Paragraphs (a) and (b) of General License 3 (this content is no longer available) authorize all transactions related to, the provision of financing for, and other dealings in bonds that are either listed in the Annex to General License 3 or that were issued both (i) prior to August 25, 2017, and (… Read more
After 12:01 a.m. eastern daylight time, April 28, 2019, as described in Venezuela-related General License 7 and General License 12, any transactions (including swaps and non-cash transactions) involving the purchase or exchange of petroleum or petroleum products in which PdVSA or any entity in… Read more
Yes. Venezuela-related General License 10 authorizes U.S. persons in Venezuela to purchase refined petroleum products, including gasoline, for personal, commercial, or humanitarian uses from PdVSA, or any entity in which it owns, directly or indirectly, a 50 percent or greater interest. General… Read more
No. Non-U.S. persons would not risk exposure under U.S. sanctions for engaging in activities or facilitating transactions or payments for such activities that would be authorized for U.S. persons pursuant to Venezuela GL 40C …
For purposes of Venezuela GL 40C , the term liquefied petroleum gas refers to the definition provided by the U.S. Energy Information Administration – a group of hydrocarbon gases, primarily propane, normal butane, and isobutane, derived from crude oil refining or natural gas processing. These gases… Read more