Venezuela General License 40C - Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela

Date issued: Jul. 08 2024

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TURBOFAC Commentary (303 words)

Notes:

1) See related FAQs FAQ # 914 and FAQ # 915.

2) This GL continues the trend of the issuance of GLs with an authorization section that refers to "all transactions and activities related to" otherwise prohibited activities, thereby making it so U.S. persons can facilitate or otherwise be involved in underlying transactions that do not otherwise involve U.S. persons (e.g., the processing of payments).

3) Note that the authorization does not authorize any activities otherwise prohibited by EO 13808, e.g. payments owed by PDVSA or the Government of Venezuela for covered products that exceed the applicable "new debt" tenor. This fact takes on particular importance given the exclusion from the GL of transactions related to "[a]ny payment-in-kind of petroleum or petroleum products." ...