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Updated on April 17, 2024
Frequently Asked Questions Related to the Suspension of Certain U.S. Sanctions with Respect to Venezuela on October 18, 2023[1]
[1] Prior versions of this document, titled “Frequently Asked Questions Related to the Suspension of Certain U.S. Sanctions with Respect to Venezuela on October 18, 2023,” were issued on October 18, 2023, November 16, 2023, and February 2, 2024. The version issued on February 2, 2024 was replaced and superseded by this version, dated April 17, 2024.
Effective April 17, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) replaced General License (GL) 44, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela” with a limited wind-down authorization. As described below, pursuant to GL 44A, U.S. persons will have until May 31, 2024 to wind down any transactions that were previously...
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1) The initial version of this preface and FAQ does not provide interpretive guidance concerning the scope of any of the authorities cited. Refer to comments to Venezuela General License 3, Venezuela General License 9, Venezuela General License 43 and Venezuela General License 44 for further comments.
2) The version revised on 2-2-24 formalizes OFAC's intent to not renew Venezuela General License 44 “absent progress between Maduro and his representatives and the opposition Unitary Platform”. See Venezuela GL 43A in re: Minerven.
3) The version revised on 4-17-24 provides guidance concerning the scope and operation of the Venezuela General License 44A wind-down license. OFAC notes that “[e]ntering into new business, including new investment, that was previously authorized under GL 44 will not be considered wind-down activity,” which is generally consistent with OFAC’s...