933. Are the authorizations in paragraph (a) of Venezuela-related General Licenses 7C and 20B, respectively, expired?
No. The authorizations in paragraph (a) of Venezuela-related General Licenses (GLs) 7C (“Authorizing Certain Activities Involving PDV Holding, Inc. and CITGO Holding, Inc.”) and 20B (“Authorizing Official Activities of Certain International Organizations Involving the Government of Venezuela”), respectively, have not expired and remain in effect. The activities described in paragraph (a) of GLs 7C and 20B, respectively, are authorized for an 18-month period, which renews automatically for an additional 18 months on the first day of each month, unless the respective GL is modified or revoked.
In the case of GL 7C, the authorization in paragraph (b), which relates to the purchase and importation of petroleum and petroleum products from Petróleos de Venezuela, S.A., expired on April 28, 2019. The authorization in GL 7C paragraph (b) does not automatically renew and is no longer in effect.
Date Released
October 1, 2021
Paragraph (a) of Venezuela-related General Licenses (GLs) 7C and 20B contain the following language:
"This authorization automatically renews on the first day of each month, and is valid for a period of 18 months from the effective date of General License [No. 20B/No. 7C] or the date of any subsequent renewal of General License [No. 20B/No. 7C], whichever is later."
The FAQ appears to stand for the proposition that the effect of "[t]his authorization automatically renews on the first day of each month" is to make it so the "the effective date of General License" is the first day of any given month that the GLs remain in effect. This is not at all obvious from the four corners of the GL, since "effective date" is not a defined term (and to the extent it is defined in the VSR at 591.302, that definition is of no help).
As of the date on which this FAQ was published, Venezuela GLs 7C and 20B were the only two active GLs to contain that “automatically renews” language.