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1245. What activities are authorized by Venezuela General License (GL) 52, "Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A."?
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 established U.S. entities. Transactions authorized by GL 52 include activities related to:
• the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan oil or petroleum products of Venezuelan-origin oil and petroleum products;
• the provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors;
• entry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products...
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1) As discussed in the comments to Venezuela GL 52, GL 52 authorizes all transactions “involving” PdVSA, except for the transactions carved out of the GL and transactions prohibited by VSR EOs other than EO 13850 and EO 13884. This FAQ contains a set of statements that are more “for the avoidance of doubt” than something that resolves what might otherwise be a difficult interpretive question. The five categories of transactions described as authorized is an open list. As it relates to “entry into new investment contracts” and “formation of new joint ventures,” careful attention must be given to the limitations concerning transitions prohibited by EO 13808 (new debt/equity) and EO 13835.