31 CFR § 538.536 - Activities relating to the petroleum and petrochemical industries in the Republic of South Sudan.

Date issued: Dec. 08 2011

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TURBOFAC Commentary (382 words)

Notes:

1) When this GL was issued, there was a comprehensive embargo targeting the country of Sudan, and no sanctions targeting South Sudan. OFAC issued this GL, authorizing "[a]ctivities relating to the petroleum and petrochemical industries in the Republic of South Sudan," to authorize transactions involving Sudan that were sufficiently "relating to the petroleum and petrochemical industries in the Republic of South Sudan" to qualify for the GL.

Up through late 2023, this GL and OFAC's interpretations thereof did not appear to have much ongoing interpretive import, Venezuela General License 44 (October 18, 2023) authorizes certain "transactions...that are related to oil or gas sector operations in Venezuela," so there seems to be a parallelism between the two GLs as it relates to the "relating/related to" and "in" elements of the GLs.

More specifically, as it relates to the Venezuela GL, there...