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 At the time of relaxation of these U.S. sanctions, OFAC indicated they were conditional and could be rescinded if commitments were not met.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.

Posted in Sanctions, Venezuela
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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 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 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 Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

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