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On November 24, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8I, “Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities.” This general license continues to…

On September 10, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5H, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After January 21, 2022,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the…

On July 12, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.”  This general license authorizes all transactions and activities related to the exportation or reexportation, directly or indirectly, of liquefied petroleum…

On June 17, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three general licenses related to the sanctions programs of Iran (General License N), Syria (General License 21) and Venezuela (General License 39), “Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19)…

On June 1, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8H, “Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities.” This general license continues to…

On January 15, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule implementing further provisions of the Export Control Reform Act of 2018 by: (i) imposing additional export license requirements under the Export Administration Regulations (EAR) in connection with certain military-intelligence end uses and end users; (ii) clarifying…

On January 19, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned and placed on the Specially Designated Nationals (SDN) List three individuals, fourteen entities, and six vessels for their involvement in a network attempting to evade U.S. sanctions on Venezuela’s oil sector.  According to a press release, the “illegitimate…

On December 23, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice in which it amends the Export Administration Regulations (EAR) by adding a new Military End User (MEU) List. This list identifies entities that BIS has determined are military end users for purposes of the “military end…