Frequently Asked Questions

1242. What does Venezuela General License (GL) 50A authorize?

GL 50A authorizes, subject to its conditions and exclusions, transactions prohibited by the Venezuela Sanctions Regulations (VSR) that are related to oil or gas sector operations in Venezuela of the entities listed in the Annex to GL 50A and their subsidiaries. Transactions authorized by Venezuela… Read more

513. Do the prohibitions imposed pursuant to E.O. 13808 and subsequent Venezuela-related E.O.s also extend to entities owned 50 percent or more by the Government of Venezuela?

… owned or controlled by the Government of Venezuela. This would normally include entities owned 50 percent or more by the Government of Venezuela because in most instances such entities would … controlled by the Government of Venezuela. Also included are any entities that are less… Read more

659. Does Venezuela-related General License 12 authorize U.S. persons to export goods, services, and technology from the United States to Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest during the wind-down period?

… of diluents) involving PdVSA or any entity in which it owns, directly or indirectly, a 50 percent or greater interest (other than ALBA de Nicaragua (ALBANISA) or any entity in which ALBANISA owns, directly or indirectly, a 50 percent or greater interest) …… Read more

680. Does the blocking of the Government of Venezuela impact the ability of U.S. persons to transact with the Government of Venezuela, or persons in which the Government of Venezuela owns, directly or indirectly, a 50 percent or greater interest?

… of Venezuela, or persons in which the Government of Venezuela owns, directly or indirectly, a 50 percent or greater interest. U.S. persons are not prohibited from engaging in transactions … the definition of Government of Venezuela and persons that are owned, directly or… Read more

1243. What authorizations exist to develop oil or gas projects in Venezuela for companies that are not listed in Venezuela General License (GL) 50A (Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities)?

Entities not identified in the Annex to GL 50A can rely on other authorizations to support the development of oil or gas projects in Venezuela. For example, such companies can enter into contingent contracts for new investments in the Venezuela oil or gas sectors pursuant to GL 49 and submit a… Read more

651. What happened to the Petróleos de Venezuela, S.A. (PdVSA) bonds, or bonds issued by any entity directly or indirectly owned 50 percent or more by PdVSA, that were previously included in the Annex to General License 3?

… Bonds issued by PdVSA or any entity in which it owns, directly or indirectly, a 50 percent or greater interest that was previously listed in the Annex to General License 3 (this … de Venezuela, S.A. (PdVSA) bonds, or bonds issued by any entity directly or indirectly owned… Read more

658. Can U.S. persons purchase, or engage in other transactions including swaps and non-cash transactions involving the purchase or exchange of, petroleum and petroleum products, if Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest is not directly involved in the transaction?

… or petroleum products in which PdVSA or any entity in which it owns, directly or indirectly, a 50 percent or greater interest has a direct or indirect interest will be prohibited for U.S. … or non-cash agreement owed to PdVSA or any entity in which it owns, directly or indirectly… Read more

656. Can U.S. persons in Venezuela purchase gasoline or other refined petroleum products from Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest?

… or humanitarian uses from PdVSA, or any entity in which it owns, directly or indirectly, a 50 percent or greater interest. General License 10 authorizes, among other things, purchases of … Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly… Read more

596. Does E.O. 13835 prohibit me from attaching and executing against assets of the Government of Venezuela, including vessels, properties, or financial assets, if I have a legal judgment against the Government of Venezuela?

… the E.O.), or (ii) an equity interest in any entity in which the Government of Venezuela has a 50 percent or greater ownership interest (per subsection 1(a)(iii) of the E.O.). OFAC … for attachment of equity interest in any entity in which the Government of Venezuela has a… Read more

654. With regard to Venezuela-related General License 11, “Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with Petróleos de Venezuela, S.A.,” are U.S. financial institutions required to reject funds transfers involving both Petróleos de Venezuela, S.A. (PdVSA) or entities owned, directly or indirectly, 50 percent or more by PdVSA, and a non-U.S. entity located in a country other than the United States or Venezuela?

… contracts, or other agreements involving PdVSA or entities owned, directly or indirectly, 50 percent or more by PdVSA that were in effect prior to January 28, 2019. The authorization is … block, funds transfers that involve both PdVSA or any entity owned, directly or indirectly… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence