On January 7, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5J, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After April 20, 2023,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO

On January 17, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three amended General Licenses (GLs) regarding the continued authorization of certain limited activities in Russia or involving Russian entities. 

  • Russia-related General License 6C, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates,

On December 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published preliminary guidance on how the United States will implement a price cap policy on petroleum products of Russian origin. OFAC notes that with this preliminary guidance the agency will likely “take a similar approach for Russian petroleum products as

On December 15, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was adding Russian banks and financial services entities as well as additional Russian persons to the Specially Designated Nationals (SDN) List in order to further isolate Russia from global markets. For additional information on these entities and

On November 21, 2022, the Department of the Treasury issued a Determination pursuant to Executive Order 14071 (prohibiting new investment in and the provision of certain services to the Russian Federation, see Update of April 7, 2022), that prohibits the following categories of services related to the maritime transport of crude oil of Russian

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

On November 26, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8K, extending authorization until May 26, 2023 for certain activities previously authorized under General License 8J. General License 8K authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of

On November 10, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8D extending the authorization to conduct transactions involving Vnesheconombank, Bank Financial Corporation Otkritie, Sberbank, VTB Bank, Alfa-Bank, and the Central Bank of Russia that are related to energy until May 15, 2023. The original