October 19, 2023

OFAC Issues General Licenses Easing Sanctions on Venezuela After Maduro Government and Opposition Reach Agreement on 2024 Elections

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On October 17, 2023, the Government of Nicolás Maduro and opposition parties in Venezuela entered into an agreement on an “electoral roadmap,” including international monitoring, for elections that are expected to be held in Venezuela in the second half of 2024. The following day, the Office of Foreign Assets Control (“OFAC”) of the US Department of the Treasury issued six Venezuela-related General Licenses (the “General Licenses”). Each of the General Licenses operates to authorize certain transactions or activities involving Venezuela that would otherwise be prohibited under the prevailing US-Venezuela sanctions program. Specifically, the General Licenses focus on dealings and activities involving Venezuela’s oil and gas sector and gold sector, debt and equity of Petróleos de Venezuela, S.A. (“PdVSA”), and any entity in which it owns, directly or indirectly, a 50% or greater interest (collectively, together with PdVSA, the “PdVSA Entities”), and certain Venezuelan sovereign debt. 

The issuance of the General Licenses serves not only to recognize the concessions made by the Maduro government toward allowing democratic elections in Venezuela but also to incentivize the Maduro government to take additional steps toward further democratization, including the reinstatement of candidates who are currently barred from running for public office and the release of political prisoners and wrongfully detained Americans. Toward this end, the General License for resumption of oil and gas sector operations in Venezuela is scheduled to expire, unless renewed, after six months and OFAC has emphasized that any of the General Licenses may be revoked at any time if the Maduro government does not comply with its relevant commitments to the Venezuelan opposition. 

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