On November 26, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41 authorizing all transactions ordinarily incident and necessary to certain activities for or related to the operation and management by Chevron Corporation or its subsidiaries (“Chevron”) of Chevron’s joint ventures in Venezuela (collectively, the “Chevron JVs”) involving Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns, directly or indirectly, a 50% or greater interest, that are prohibited by current U.S. sanctions in place toward Venezuela. Authorized activities under GL41 are:

  1. Production and lifting of petroleum or petroleum products produced by the Chevron JVs, and any related maintenance, repair, or servicing of the Chevron JVs;
  2. Sale to, exportation to, or importation into the United States of petroleum or petroleum products produced by the Chevron JVs, provided that the petroleum and petroleum products produced by the Chevron JVs are first sold to Chevron;
  3. Ensuring the health or safety of personnel or the integrity of operations or assets of the Chevron JVs in Venezuela; and
  4. Purchase and importation into Venezuela of goods or inputs related to the three activities described above, including diluents, condensates, petroleum, or natural gas products.

This GL has a number of restrictions on Chevron’s activities in Venezuela, including the following activities that remain prohibited:

  • The payment of any taxes or royalties to the Government of Venezuela;
  • The payment of any dividends to PdVSA, or any entity in which PdVSA owns, directly or indirectly, a 50% or greater interest;
  • The sale of petroleum or petroleum products produced by or through the Chevron JVs for the exportation to any jurisdiction other than the United States;
  • Any transaction involving an entity located in Venezuela that is owned or controlled by an entity located in the Russian Federation;
  • Any expansion of the Chevron JVs into new fields in Venezuela beyond what was in place on January 28, 2019; or
  • Any transactions otherwise prohibited by current U.S. sanctions toward Venezuela, unless separately authorized.

OFAC has announced that GL41 will be automatically renewed on the first day of each month and is valid for a period of six months from the effective date of each renewal. In clarifying FAQs, OFAC has indicated that non-U.S. persons do not risk exposure to sanctions for facilitating transactions that are authorized under this GL. In addition, U.S. persons may provide goods or services to Chevron for certain activities related to the operation and management of Chevron’s joint ventures in Venezuela, as specified in this GL.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

Read more about Scott E. Diamond**
Show more Show less
Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Read more about Francesca M.S. Guerrero
Show more Show less
Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Read more about Samir D. Varma
Related Posts
OFAC Extends Winding Down Deadline of Venezuela General License 41
March 25, 2025
OFAC Once Again Extends Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
March 7, 2025
Reversing the Biden Administration, OFAC Announces the Wind Down of Venezuela General License 41
March 5, 2025