OFAC - Venezuela General License 11 - Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with Petróleos De Venezuela, S.A. (PdVSA)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (588 words)

Notes:

1) Venezuela 11 (EO 13850) and Venezuela GL 12 are complimentary. The scope of GL 11 extends to "maintenance of operations," while GL 12 is limited only to "wind down of operations." This GL has expired.

2) See FAQ 625 and FAQ 648 for guidance on the scope of the term "maintenance," and consult the Research System for guidance on "wind down" situations. The scope of "operations...involving PdVSA...that were in effect prior to January 28, 2019" is difficult to pin down, particularly with respect to "contractors" and other service providers. This GL would not seem to permit, for example, U.S. person insurance companies to insure shipments of PdVSA oil not involving the U.S.

3) Subsection (b) of GL 11 is essentially limited to what are referred to as "U-turn" transactions,...

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Venezuela General License 11 - Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with Petróleos De Venezuela, S.A. (PdVSA)

TURBOFAC Commentary (588 words)