On April 26, 2011, OFAC issued General License No. 5 pursuant to Executive Order 13566 of February 25, 2011, "Blocking Property and Prohibiting Certain Transactions Related to Libya" ("E.O. 13566"). General License No. 5 authorizes U.S. persons to engage in transactions with or involving Qatar Petroleum or the Vitol group of companies related to oil, gas, or petroleum products exported from Libya under the auspices of the Transitional National Council of Libya (the "TNC"), provided that neither the Government of Libya nor any other person whose property and interests in property are blocked – with the exception of Arab Gulf Oil Company ("Agoco"), as an entity operating in areas controlled by the TNC and under the auspices of the TNC – receives any benefit from such transactions.
Also on April 26, OFAC issued a Statement of Licensing Policy establishing a favorable licensing regime through which U.S. persons can request from OFAC specific authorization to trade in hydrocarbon fuel (i.e., oil, gas, and petroleum products), as well as authorization to support or facilitate the trade in such hydrocarbon fuel, to the extent that such hydrocarbon fuel is exported under the auspices of the TNC. U.S. persons also can request specific licenses to engage in transactions related to the production of oil, gas, and petroleum products in areas controlled by the TNC.
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