On March 4, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 41A within its Venezuela-Related Sanctions Program: “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela.” The Biden Administration had issued the precursor to General License (GL) 41A, GL 41, on November 26, 2022, to permit Chevron Corporation’s joint ventures with Petróleos de Venezuela, S.A. (PdVSA) or any entity owned 50% or more by PdVSA, whether directly or indirectly, to operate in Venezuela. PdVSA is Venezuela’s state-owned oil and natural gas company. (For more background on GL 41, see Thompson Hine Update of November 28, 2022.) OFAC’s issuance of GL 41A comes a few days after President Donald Trump stated his administration would be “reversing the concessions” of GL 41, arguing Venezuela’s leadership has made insufficient progress on reforming the “[e]lectoral conditions within Venezuela” and on “the rapid pace that they had agreed to” accept migrant returns from the United States.
Under the conditions set forth in GL 41A, all transactions “ordinarily incident and necessary to the wind down of transactions” are permissible until 12:01 a.m. eastern daylight time, April 3, 2025. Thereafter, transactions previously authorized under GL 41 will be prohibited.