Key Notes:

  • For a period of six months, OFAC permits a wide range of transactions tied to Venezuela’s oil and gas sector, including new investments and financial dealings with specific Venezuelan banks.
  • OFAC allows all forms of transactions with Minerven, the Venezuelan state-owned gold mining company, nullifying prior sanctions solely in this sector.
  • OFAC lifted restrictions on secondary trading of selected Venezuelan sovereign bonds and debt and equity related to PdVSA, enabling both purchase and sale within the U.S. market.
  • These licenses are conditional; OFAC retains the right to rescind if conditions are not met.
  • Other sanctions on Venezuela remain in effect.

On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued several new and amended Venezuela-related General Licenses (GL) authorizing various transactions that would otherwise be prohibited. These developments occurred in response to a political agreement between Venezuelan President Nicolás Maduro’s representatives and the Unitary Platform as a step forward in restoring democracy in Venezuela. According to the Department of the Treasury, this easing is conditional and could be rescinded if commitments are not met. All other sanctions on Venezuela remain in effect.

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Posted in OFAC, Sanctions, Venezuela
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.

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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.

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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.

**Not licensed to practice law.

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Photo of Kristina Shcheglazova* Kristina Shcheglazova*

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control…

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control matters, including compliance with various sanctions and export control requirements, due diligence and sanctions screenings, and advises clients on the application of U.S. sanctions and export control licensing requirements. Her experience extends to addressing issues of forced labor in supply chains, assisting clients with government contracting matters and advising on anti-corruption policies.

*Licensed in MO only, not IL; limited to federal practice only.

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