On January 30, 2024, the Department of State announced in a press release that the United States would be reinstating certain sanctions actions on Venezuela in light of recent activities by President Nicolás Maduro and his regime, including the recent barring of opposition candidates from competing in Venezuela’s 2024 presidential election.
In October 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued several new Venezuela-related General Licenses authorizing various transactions that would otherwise be prohibited under U.S. sanctions toward Venezuela. These earlier developments were in response to a political agreement between Maduro’s representatives and the Unitary Platform that appeared to indicate a step forward in restoring democracy in Venezuela. At the time of relaxation of these U.S. sanctions, OFAC indicated they were conditional and could be rescinded if commitments were not met. See Thompson Hine Update of October 24, 2023, for additional details on the original relaxation of sanctions.
Given recent suppression of the democratic opposition in Venezuela, two OFAC-issued Venezuela General Licenses (GL) will be impacted:
- Venezuela GL 43 authorized transactions involving CVG Compania General de Mineria de Venezuela CA, the Venezuelan state-owned gold mining company. This GL is revoked as of February 13, 2024, and U.S. persons have 14 days to wind down any transactions that were previously authorized by this GL.
- Venezuela GL 44 temporarily authorized all transactions that are related to the oil and gas sector operations in Venezuela that would otherwise be prohibited under the Venezuelan Sanctions Regulations. According to the State Department’s press release, “Absent progress between Maduro and his representatives and the opposition Unitary Platform, particularly on allowing all presidential candidates to compete in this year’s election,” this GL will not be renewed when it expires on April 18, 2024.
It is assumed that at a later date, OFAC will revise its Venezuela FAQs to address the resumption of these sanctions. All other sanctions on Venezuela remain in effect.