Episode 426 — Venezuela Sanctions Update: OFAC’s New General Licenses and the FGDF Framework (Part 1)

Michael Volkov examines OFAC’s new Venezuela general license framework—including General License 52, General License 46B, and the newly effective General License 51B covering Venezuelan-origin minerals—analyzing how these authorizations create conditional pathways for otherwise-prohibited energy and minerals transactions while preserving the underlying blocking regime applicable to PdVSA and the Government of Venezuela. Michael explains the established U.S. entity eligibility requirement, the mandatory contractual conditions requiring U.S. governing law and U.S. dispute resolution in agreements with Venezuelan governmental counterparties, and the critical jurisdictional restrictions excluding transactions with Russia, Iran, Cuba, North Korea, and China-connected entities. The episode provides a detailed operational breakdown of the Foreign Government Deposit Fund payment mechanism established under Executive Order 14373—including the [email protected] submission process and documentary requirements—and concludes with an analysis of the multi-agency reporting obligations triggered under each applicable authorization.

You may also like...

Leave a Reply

Your email address will not be published. Required fields are marked *