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1226. Does "Venezuelan-origin oil" as referenced in Venezuela General License (GL) 46, "Authorizing Certain Activities Involving Venezuelan-Origin Oil," include petroleum products?
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 nationality of the entity involved in the production or sale of such crude oil or petroleum products.
As defined by the U.S. Energy Information Administration (EIA), petroleum products include unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas, and miscellaneous products obtained from the processing of crude oil (including lease condensate), natural gas, and other...
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1) See comments to Venezuela GL 46 for consolidated comment on the GL.
2) This FAQ adopts an extremely broad definition of the term “oil” for purposes of GL 46. For the EIA definition of “petroleum products,” see https://www.eia.gov/tools/glossary/index.php?id=Petroleum%20products. OFAC appears to be taking the view that, at a minimum, everything within the scope of the EIA definition qualifies as “oil” for purposes of the GL, so there may be a need to cross-reference laws and regulations other than those administered by OFAC to determine what unnamed products are covered by the GL (i.e. the “miscellaneous products obtained from the processing of crude oil (including lease condensate), natural gas, and other hydrocarbon compounds”).