ARTICLE
14 July 2021

OFAC Authorizes Petroleum Gas Transactions Involving Venezuelan Government, PdVSA

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OFAC authorized transactions related to the exportation or re-exportation of liquefied petroleum gas to Venezuela involving the Government of Venezuela or Petróleos de Venezuela, S.A. ("PdVSA"). The authorizations run through July 8, 2022.
United States International Law
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OFAC authorized transactions related to the exportation or re-exportation of liquefied petroleum gas to Venezuela involving the Government of Venezuela or Petróleos de Venezuela, S.A. ("PdVSA"). The authorizations run through July 8, 2022. The transactions permitted through this general license would otherwise be prohibited under Executive Order ("EO") 13850 ("Blocking Property of Additional Persons Contributing to the Situation in Venezuela"), as amended by EO 13857 ("Taking Additional Steps to Address the National Emergency with respect to Venezuela"), or EO 13884 ("Blocking Property of the Government of Venezuela").

In the General License ("GL") No. 40, OFAC specified that the authorization does not extend to (i) any payment-in-kind of petroleum or petroleum products or (ii) any transactions otherwise prohibited by the Venezuela Sanctions Regulations. OFAC also stated that GL No. 40 does not relieve compliance with the requirements of the Department of Commerce's Bureau of Industry and Security.

OFAC published two related FAQs to (i) define liquefied petroleum gas (citing the U.S. Energy Information Administration's definition), and (ii) clarify that non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized for U.S. persons under this general license.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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