Venezuela General License 41A - Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation's Joint Ventures in Venezuela

Date issued: Mar. 04 2025

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TURBOFAC Commentary (512 words)

Notes:

[On 3-4-25, OFAC replaced GL 41 with GL 41A, authorizing (through April 3, 2025) “all transactions ordinarily incident and necessary to wind down of transactions previously authorized by Venezuela General License 41”. The carveouts are the same in both licenses, except that in GL 41A there is no carveout for “Any expansion of the Chevron JVs into new fields in Venezuela beyond what was in place on January 28, 2019”. OFAC likely regarded any such activities as inherently outside the scope of a “wind down” that cross-referenced GL 41. The below has not been updated to reflect this fact. Refer generally to Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs.]

1) Read in conjunction with FAQ # 1098 and FAQ # 1099 (non-U.S....