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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. 47
Authorizing the Sale of U.S.-Origin Diluents to Venezuela
(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 exportation, reexportation, sale, resale, supply, storage, marketing, delivery, or transportation of U.S.-origin diluents to Venezuela are authorized, provided that any contract for such transactions with the Government of Venezuela, PdVSA, or PdVSA Entities specify that the laws...
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*This is one of several Venezuelan energy sector-related GLs issued since the U.S. military operation resulting in the capture of Nicolás Maduro. See Venezuela General License 46A, Venezuela General License 47, Venezuela General License 48, Venezuela General License 49 and Venezuela General License 50.
1) Compare/contrast Venezuela General License 46 (a “sister” GL modeled in a similar fashion). The GLs are modeled in a similar fashion and cover similar activities. Below are certain observations and interpretive questions that arise from the GL, especially when read in light of GL 46, which OFAC has yet to address with formal guidance.
a) How will “U.S. origin” be interpreted? A broad interpretation is “subject to the EAR,”...