Venezuela General License 8H - Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities [PDF File Contains All Versions]

Date issued: Jun. 01 2021

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TURBOFAC Commentary (1490 words)

Notes: (PDF File Contains All Versions)

1) This is one of 12 GLs that pre-dated the blocking of the Government of Venezuela (GOV), pursuant to EO 13884. It was amended in Aug. of 2019 to account for the blocking of the GOV.

2) With respect to the carveout for diluents, see FAQ # 672, and comments thereto, for a discussion on the proposition that "[a]ny transactions or dealings related to the exportation or reexportation of diluents, directly or indirectly, to Venezuela," are at the threshold level, prohibited by one or more of the Venezuela-related EOs in force as of June 6, 2019.

3) In the interim between when this GL was initially issued and when it was first amended, the president of PdVSA was designated pursuant to EO 13692, an EO for which no...