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1227. What activities does Venezuela General License (GL) 46 authorize?
GL 46 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, purchase, delivery, or transportation of Venezuelan-origin oil by an established U.S. entity, which may include:
• engaging in commercial, legal, and technical discussions necessary to scope purchases of Venezuelan-origin oil, including with third-party legal, commercial, or due diligence consultants;
• conducting safety, environmental, and other relevant inspections, including site surveys;
• arranging logistics, security services, delivery points, and shipping preparation, including obtaining marine insurance and engaging with relevant port or maritime authorities of the Government of Venezuela (GOV) or their personnel;
• conducting certain downstream activities, including the refining and resale of Venezuelan-origin...
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1) See comments to Venezuela GL 46 for consolidated comment on the GL.
2) This FAQ provides a helpful illustrative list, beyond that which is described in the interpretive note contained in the GL of 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, purchase, delivery, or transportation of Venezuelan-origin oil”. Note that OFAC also defines the term “lifting” in this FAQ, which appears aimed at clarifying that the GL does not cover exploration and pre-lifting production activities.
3) While this at least partially an interpretation of the term “ordinarily incident and necessary” as it appears in the text of...