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1267. Do certain Venezuela General Licenses (e.g., 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A) require a choice of law provision in contracts with the Government of Venezuela?
No. Effective August 27, 2026, parties seeking to enter into a contract authorized by certain Venezuela General Licenses (GLs) (e.g., 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A) with the Government of Venezuela (GOV) or certain other blocked persons (e.g., Petróleos de Venezuela, S.A. in GL 52B or CVG Compañía General de Minería de Venezuela CA in GL 51C) are no longer required to include a choice of law provision in the contract. On August 27, 2026, OFAC amended these GLs to remove the requirement that the terms of such contracts be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States.
OFAC amended these GLs in response...
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1) See GLs referenced in the FAQ, and comments thereto. Prior to 8-27-26, there was a provision requiting all contracts with blocked persons to be such that “the terms of the contract be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States”. This is no longer the case.