After Venezuela’s government and its political opposition agreed on electoral guarantees for 2024 presidential elections, the Office of Foreign Assets Control (OFAC) issued four general licenses suspending select sanctions:
- General License 44 temporarily authorizes all transactions related to Venezuelan oil and gas sector operations, including producing, lifting, selling, and exporting oil or gas from Venezuela and new investment in oil or gas sector operations. The authorization includes transactions involving Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA directly or indirectly owns a 50% or greater interest.
The license expires on April 18, 2024. OFAC will only renew the license if Maduro’s government follows through with its commitments and continues taking measurable steps toward democratic elections in 2024.
- General License 43 authorizes transactions involving CVG Compania General de Mineria de Venezuela CA (known as Minerven), the state-owned gold mining company.
- General License 3I and General License 9H remove the secondary market trading bans on buying certain Venezuelan sovereign bonds, as well as pre-2017 PdVSA bonds or equity.
Although General License 44 affects the oil and gas sectors broadly, the following are still prohibited:
- Transactions with sanctioned financial institutions, other than Banco Central de Venezuela or Banco de Venezuela SA Banco Universal
- Providing goods or services to, or new investment in, any entity in Venezuela that is owned or controlled by, or a joint venture with, an entity in Russia
- Transactions related to new investment in Venezuela’s oil or gas sector operations by a person located in Russia or an entity owned or controlled by a person in Russia
- Certain financial transactions enumerated in Executive Order 13808
- Transactions prohibited by Executive Order 13827 or Executive Order 13835
- Unblocking property blocked under the Venezuelan Sanctions Regulations
- Transactions with blocked persons
As with any general license, OFAC can revoke the authorizations in the interests of U.S. foreign policy or national security.