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 JVs”) involving Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, that are prohibited by current U.S. sanctions in place toward Venezuela. Authorized activities under GL41 are:
- Production and lifting of petroleum or petroleum products produced by the Chevron JVs, and any related maintenance, repair, or servicing of the Chevron JVs;
- Sale to, exportation to, or importation into the United States of petroleum or petroleum products produced by the Chevron JVs, provided that the petroleum and petroleum products produced by the Chevron JVs are first sold to Chevron;
- Ensuring the health or safety of personnel or the integrity of operations or assets of the Chevron JVs in Venezuela; and
- Purchase and importation into Venezuela of goods or inputs related to the three activities described above, including diluents, condensates, petroleum, or natural gas products.
This GL has a number of restrictions on Chevron’s activities in Venezuela, including the following activities that remain prohibited:
- The payment of any taxes or royalties to the Government of Venezuela;
- The payment of any dividends to PdVSA, or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest;
- The sale of petroleum or petroleum products produced by or through the Chevron JVs for the exportation to any jurisdiction other than the United States;
- Any transaction involving an entity located in Venezuela that is owned or controlled by an entity located in the Russian Federation;
- Any expansion of the Chevron JVs into new fields in Venezuela beyond what was in place on January 28, 2019; or
- Any transactions otherwise prohibited by current U.S. sanctions toward Venezuela, unless separately authorized.
OFAC has announced that GL41 will be automatically renewed on the first day of each month and is valid for a period of six months from the effective date of each renewal. In clarifying FAQs, OFAC has indicated that non-U.S. persons do not risk exposure to sanctions for facilitating transactions that are authorized under this GL. In addition, U.S. persons may provide goods or services to Chevron for certain activities related to the operation and management of Chevron’s joint ventures in Venezuela, as specified in this GL.