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DEPARTMENT OF THE TREASURY
WASHINGTON, D.C.
OFFICE OF FOREIGN ASSETS CONTROL
Venezuela Sanctions Regulations
31 CFR part 591
GENERAL LICENSE NO. 46
Authorizing Certain Activities Involving Venezuelan-Origin Oil
(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), including those involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), that are ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, including the refining of such oil, by an established U.S. entity are authorized, provided that:
(1) Any contract for such transactions with the Government...
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1) This is the first Venezuela-related GL issued by the second Trump Administration. It follows the U.S. naval “blockade” around Venezuela and seizure of oil tankers departing Venezuela, the military operation resulting in the capture of Nicolás Maduro, the elevation of Delcy Rodríguez from Vice President to Acting President of Venezuela, and a “sweeping reform” to Venezuela’s hydrocarbons law which favors private actors operating in the country (see https://www.spglobal.com/energy/en/news-research/latest-news/crude-oil/011526-new-venezuela-hydrocarbons-law-to-include-production-participation-contracts-rodrguez). As of this writing, the GL is yet to be interpreted by official FAQ guidance or otherwise discussed on record by Administration officials in a way that would provide insight into the scope and operation of the GL.
2) The GL resembles the broader Venezuela General License 44 in some respects, but is sui generis in many respects in terms of the novel...