Venezuela General License 44A - Authorizing the Wind Down of Transactions Related to Oil or Gas Sector Operations in Venezuela (PDF includes previous version)

Date issued: Apr. 17 2024

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TURBOFAC Commentary (2218 words)

Notes:

[Update: on 4-17-24, OFAC issued GL 44A, a ~six-week wind-down GL for all activities previously authorized by GL 44. The analysis below has not been altered to reflect the issuance of GL 44A. See https://www.state.gov/venezuela-sanctions-relief-expiration-of-general-license-44. Concurrent with this action, OFAC issued revised Venezuela GL 44-related FAQs See October 18, 2023 Venezuela Looseleaf FAQ - # 1 (wind-down/targeting criteria), October 18, 2023 Venezuela Looseleaf FAQ - # 2 (specific licensing policy) and October 18, 2023 Venezuela Looseleaf FAQ - # 3 (Crystallex litigation), and comments thereto].

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1) GL 44 is unique to the VSR, and "the U.S. government announced that absent progress between Maduro and his representatives and the opposition Unitary Platform, particularly on allowing all presidential candidates to compete in this year’s election, the United States will...