Frequently Asked Questions

GL 46B authorizes activities that are ordinarily incident and necessary to the lifting (which refers to the physical loading and removal of oil from a terminal, storage facility, or production site for delivery to a buyer), exportation, reexportation, sale, resale, supply, storage, marketing,… Read more

Yes. Consistent with the term "Venezuelan oil" as defined in section 5(a) of Executive Order 14245 , "Imposing Tariffs on Countries Importing Venezuelan Oil," the term "Venezuelan-origin oil" means crude oil or petroleum products extracted, refined, or exported from Venezuela, regardless of the… Read more

If a U.S. person entered into a long-term credit facility or loan agreement prior to August 25, 2017, drawdowns and disbursements with repayment terms of 90 days or less (for PdVSA) or 30 days or less (for the rest of the Government of Venezuela) are not prohibited. Drawdowns and disbursements… Read more

Executive Order 13857 of January 25, 2019 "Taking Additional Steps to Address the National Emergency with Respect to Venezuela" broadens the definition of the term "Government of Venezuela" to include persons that have acted, or have purported to act, on behalf of the Government of Venezuela,… Read more

General License (GL) 9H authorizes U.S. persons to engage in all transactions prohibited by subsection 1(a)(iii) of Executive Order (E.O.) 13808 or by E.O. 13850 , each as amended by E.O. 13857 , or by E.O. 13884 , as collectively incorporated into the Venezuela Sanctions Regulations, 31 CFR part… Read more

No. A specific license will be required before any sale is executed in the Crystallex case. Notwithstanding the existence of any general licenses under the Venezuela Sanctions Regulations (VSR), a specific license from OFAC is required for the entry into a settlement agreement, or for the… Read more

GL 52 authorizes, subject to its conditions and exclusions, transactions prohibited by Executive Orders (E.O.s) 13884 or 13850 with Petróleos de Venezuela, S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, "PdVSA Entities"), by… Read more

General License 3I (GL 3I) authorizes U.S. persons to engage in all transactions related to, the provision of financing for, and other dealings in the bonds specified in the Annex to GL 3I (GL 3I Bonds) that would be prohibited by subsection 1(a)(iii) of Executive Order (E.O.) 13808 or by E.O.… Read more

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