Frequently Asked Questions

507 … Yes, but prohibitions on dealing in new debt vary based on whether the entity involved is a PdVSA entity or another part of the Government of Venezuela. Subsection 1 (a)(i) of E.O. 13808 prohibits engaging in transactions related to, providing financing for, or otherwise dealing in debt if (1… Read more

508 … No. E.O. 13808 , as amended by E.O. 13857 , does not authorize the blocking of property. E.O. 13808, however, should be read in conjunction with other Venezuela-related authorities, such as the E.O. 13884 , which blocks the Government of Venezuela, and E.O. 13850, as amended, under which… Read more

509 … General License 1, which expired on September 25, 2017, provided a wind-down period with respect to contracts and other agreements that were in effect prior to August 25, 2017. That general license provided 30 days in which to conduct all transactions and activities otherwise prohibited by… Read more

834 … On June 18, 2020, OFAC designated pursuant to E.O. 13850 , among other entities and individuals, two entities for operating in the oil sector of the Venezuelan economy and identified two vessels owned by these entities as blocked property. Concurrent with this action, OFAC issued General… Read more

854 … On November 30, 2020, OFAC designated CEIEC pursuant to Executive Order (E.O.) 13692 for its role in undermining democracy in Venezuela.  Concurrent with this action, OFAC issued Venezuela General License (GL) 38 (“Authorizing the Wind Down of Transactions Involving CEIEC”).  GL 38 authorizes… Read more

914 … 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 . … Do non-U.S. persons risk exposure to U.S. sanctions for engaging… Read more

915 … 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… Read more

817 … On February 18, 2020, OFAC designated Rosneft Trading S.A. pursuant to E.O. 13850 for operating in the oil sector of the Venezuelan economy. Likewise, on March 12, 2020, OFAC designated TNK Trading International S.A. pursuant to E.O. 13850 for operating in the oil sector of the Venezuelan… Read more

818 … OFAC issued General License(GL) 36A, which authorizes U.S. persons to engage in certain activities prohibited by E.O. 13850​ necessary for the wind down of transactions involving Rosneft Trading S.A. or TNK Trading International S.A., or any entity in which Rosneft Trading S.A. or TNK Trading… Read more

933 … No.  The authorizations in paragraph (a) of Venezuela-related General Licenses (GLs) 7C (“Authorizing Certain Activities Involving PDV Holding, Inc. and CITGO Holding, Inc.”) and 20B (“Authorizing Official Activities of Certain International Organizations Involving the Government of Venezuela… Read more