On March 24, 2025, President Donald Trump signed an Executive Order (EO) declaring that any country purchasing oil from Venezuela, “whether directly from Venezuela or indirectly through third parties,” will pay a 25% tariff on their exports to the United States. The EO tasks the Secretary of Commerce with determining whether a country buys Venezuelan
Venezuela
OFAC Extends Winding Down Deadline of Venezuela General License 41
On March 24, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41B extending the expiration date of Venezuela GL 41, which authorized certain transactions related to Chevron Corporation’s joint ventures in Venezuela. Previously, under GL 41A issued earlier this month, all transactions “ordinarily incident and…
OFAC Once Again Extends Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On March 6, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5R, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 3, 2025,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
Reversing the Biden Administration, OFAC Announces the Wind Down of Venezuela General License 41
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…
President Trump Issues America First Investment Policy Memorandum Impacting FDI into the U.S. and Outbound Investment to Foreign Adversaries
On February 21, 2025, President Trump issued the America First Investment Policy Memorandum (“Memorandum”). The Memorandum aims to promote foreign direct investment (FDI) from “allies and partners” while restricting inbound investment from and outbound investment to “foreign adversaries,” such as China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and the Nicolás Maduro…
OFAC Sanctions Venezuelan Officials Supporting Nicolas Maduro’s Regime
On January 10, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated and placed eight Venezuelan officials on the Specially Designated Nationals (SDN) List for “enabling Nicolas Maduro’s repression and subversion of democracy in Venezuela.” The individuals sanctioned include the president of Petroleos de Venezuela, S.A., (PdVSA), Venezuela’s state-owned oil company…
OFAC Continues to Extend Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On November 7, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8O︎, extending authorization until May 9, 2025 for certain activities previously authorized under General License 8N. General License 8O︎ authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of essential…
OFAC Again Extends Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On November 7, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5Q, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 7, 2025,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
OFAC Issues Another Extension of Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On August 12, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5P, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After November 12, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
OFAC Issues General License 40C Continuing to Authorize Certain Transactions Involving the Export of LP Gas to Venezuela
On July 8, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40C, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.” This revised general license continues authorization of all transactions and activities related to the exportation or reexportation, directly or indirectly…