The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV. Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond. OFAC issued General License (GL) 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.
General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license. Since that date, OFAC has extended the delay in effectiveness multiple times. Most recently, OFAC issued General License 5Z on September 16, 2026, which further delays the effectiveness of the authorization in GL 5 until November 5, 2026. Between October 24, 2019 and November 5, 2026 (the date the authorization in General License 5Z becomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond. As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.
To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.
VEGA SANCHEZ, Jose Raul, c/o AGRICOLA GAXIOLA S.A. DE C.V., Hermosillo, Sonora, Mexico; c/o INMUEBLES SIERRA VISTA S.A. DE C.V., Hermosillo, Sonora, Mexico; c/o TEMPLE DEL PITIC S.A. DE C.V., Hermosillo, Sonora, Mexico; DOB 19 Oct 1956; POB Cananea, Sonora, Mexico; nationality Mexico; citizen Mexico; C.U.R.P. VESR561019HSRGNL09 (Mexico); alt. C.U.R.P. VEXR561019HSRGXL05 (Mexico) (individual).
OFAC Program: [RUSSIA-EO14024] Executive Order 14024
BOMATTER, Hans Peter, La Zubia, Spain; DOB 19 May 1965; POB Schattdorf, Switzerland; nationality Switzerland; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport F3848406 (Switzerland) (individual) (Linked To: TAMYNA AG).
MODULSAN MAKINA KESICI TAKIM VE DISLI SANAYI TICARET LIMITED SIRKETI, 1CA Blok, 1575. Sokak No. 1 CA/2, Akcaburgaz Mahallesi, Esenyurt 34522, Turkey; Websitehttp://www.modulsan.com; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Organization Established Date 09 Oct 2006; Tax ID No. 3340494281 (Turkey); Identification Number 0334049428100019 (Turkey); Registration Number 602993 (Turkey).
The text of the following statement was released by the Governments of Australia, Canada, France, Germany, Italy, Japan, the Netherlands, New Zealand, the Republic of Korea, the United Kingdom, and the United States of America on the occasion of the release of the latest report of the Multilateral Sanctions Monitoring Team.
We, the participating states of the Multilateral Sanctions Monitoring Team (MSMT), have released a report today on the Democratic People’s Republic of Korea’s (DPRK) violations and evasions of United Nations Security Council resolutions (UNSCRs) through the ongoing overseas deployment of North Korean labourers. The MSMT is a multilateral mechanism established in October 2024 to monitor and report on the implementation of UN sanctions measures relating to the DPRK. The report is available on the official MSMT website.
This report details the systemic evasion of UN sanctions by the DPRK and other countries through a global network of unlawful overseas labour, prohibited by UNSCRs 2375 and 2397. The report consolidates information provided by MSMT participating states and open-source information to show how the DPRK continues to deploy an estimated 35,600 to 101,280 labourers, nearly all of whom are located in the People’s Republic of China and Russian Federation.
Despite the 2019 repatriation deadline mandated by UNSCR 2397, at least 17 countries are suspected of continuing to host labourers, generating between US $450 million and $800 million in 2025 to fund the DPRK’s unlawful nuclear weapons and ballistic missile programs. The report highlights that nearly all of the wages earned by overseas North Korean labourers are confiscated by the DPRK.
The MSMT is sharing this information with the international community to highlight the significant risks associated with employing North Korean overseas labourers and the need to deter the employment of such labourers. We encourage all UN Member States to raise awareness and hold responsible parties and facilitators accountable for UNSCR violations, including through domestic action.
This report addresses the monitoring gap created by the disbandment of the UN Security Council’s 1718 Committee Panel of Experts in April 2024, caused by Russia’s veto in March 2024. The report will assist the international community in fully implementing the relevant UNSCRs. Considering the continued violations and evasions of relevant UNSCRs, we urge the UN Security Council to reestablish the Panel of Experts in the same strength and structure it had prior to its disbandment.
We underscore once again our shared determination to fully implement the UNSCRs. The MSMT will continue to monitor the implementation of UNSCRs related to the DPRK and expose ongoing attempts by the DPRK and others to violate and evade these measures.
Quick Facts:
In 2017, the UN Security Council (UNSC) made it unlawful for any UN Member State to allow North Koreans to earn income within their jurisdictions. All countries were required to repatriate any North Koreans earning income within their jurisdictions back to the DPRK by 2019.
An estimated 20,000-70,000 North Korean labourers are deployed in China. Despite a temporary repatriation of 10,000-20,000 workers between 2023 and 2025, approximately 10,000 new North Korean labourers arrived in China between January 2025 and January 2026.
North Korean labourers are increasingly deployed to work in Russia, with 15,000-30,000 working in Russia as of the end of 2025. North Korean labourers are manufacturing military drones for Russia on Russian soil, such as in drone factories located in Russia. The Russian government has created a student visa scheme to camouflage North Korean labourers in Russia as students. Each North Korean labourer in Russia generates an average estimated US $7,500 in wages annually.
Estimates indicate that monthly wages earned by North Korean labourers in Russia may be up to five times as high compared to monthly wages in China, depending on the industry.
The DPRK confiscates 80-90% of wages earned by North Korean labourers. In some cases, the confiscated amount exceeds their actual earnings, leaving North Korean labourers indebted to the DPRK. DPRK authorities exercise extreme control over labourers’ movement and interactions with outsiders in order to prevent defections, while labourers who do defect risk reprisals against family members remaining in North Korea.
The following is a Presidential Determination submitted to Congress September 15, 2026:
By the authority vested in me as President by the Constitution and the laws of the United States, including section 706(1) of the Foreign Relations Authorization Act, Fiscal Year 2003 (P.L. 107-228) (FRAA), I hereby identify the following countries as major drug transit or major illicit drug producing countries: Afghanistan, The Bahamas, Belize, Bolivia, Burma, China, Colombia, Costa Rica, the Dominican Republic, Ecuador, El Salvador, Guatemala, Haiti, Honduras, India, Jamaica, Laos, Mexico, Nicaragua, Pakistan, Panama, Peru, and Venezuela.
A country’s presence on the foregoing list is not necessarily a reflection of its government’s current counterdrug efforts, or coordination with the United States. Consistent with the statutory definition of a major drug transit or drug producing country set forth in the Foreign Assistance Act of 1961, major drug transit or illicit drug producing countries are placed on the list due to a combination of geographic, commercial, and economic factors that allow drugs or precursor chemicals to transit or be produced, even if a government has engaged in robust and diligent narcotics control and law enforcement measures.
Pursuant to section 706(2)(A) of the FRAA, I hereby designate Afghanistan, Bolivia, Burma, and Colombia as having failed demonstrably during the previous 12 months to make substantial efforts to adhere to their obligations under international counternarcotics agreements and to take the counternarcotics measures required by 22 U.S.C. § 2291h(a)(1). Included with this determination are justifications for the designations of Afghanistan, Bolivia, Burma, and Colombia as described in section 706(2)(B) of the FRAA. I have also determined, in accordance with section 706(3)(A) of the FRAA, that provision of United States assistance to Bolivia, Burma and Colombia is currently vital to the national interests of the United States.
My Administration has made historic progress in protecting the American people from deadly drugs and vicious narcoterrorist organizations. Under my Administration, our southern border is the most sealed and secure in American history, thanks to the largest investments in border security and law enforcement in our Nation’s history. After four years of open border chaos, seizures of fentanyl and other drugs being smuggled into the United States have been reduced by more than half, and drug overdose deaths have plunged. My Administration has saved tens of thousands of American lives from this scourge. The narcoterrorists responsible for this invasion are either dead, in jail, or living in fear knowing they will be next to face American justice. I have unleashed the strongest military in the history of the world to strike narcoterrorists wherever they threaten our country. Behind the might of the American military, my Administration has destroyed cartel infrastructure, shut down former trafficking highways across sea and land borders, and captured and killed hundreds of the most vicious narcoterrorists. Under the Americas Counter Cartel Coalition, an alliance with over a dozen countries in the Western Hemisphere, we have achieved historic results, drastically reducing United States-bound drug flows and seizing billions of dollars of illicit cartel finances. United States law enforcement agencies are reporting record drug seizures, and our allies are extraditing more cartel bosses to the United States than ever before. We have inflicted unprecedented losses on our enemies, and we are just getting started.
While my Administration has successfully secured our borders from invasion, Canada and Mexico need to do far more to stop the flows of deadly drugs into our country. Fentanyl continues to be illicitly produced in clandestine Canadian labs, and precursor chemicals and synthetic drugs continue to enter the United States through Canada. Canada needs to take meaningful action to dismantle drug labs, strengthen supply chain security, and degrade criminal networks and Chinese gangs operating along our northern border. We recognize Mexican President Sheinbaum’s administration for seizing greater volumes of drugs, dismantling clandestine laboratories, and deploying additional law enforcement and military resources to our shared border. Additionally, United States-Mexican security cooperation has helped eliminate some of the world’s most notorious cartel bosses, including “El Mencho.” However, Mexico must take additional action against the narcoterrorist organizations that dominate vast areas of its territory and continue to threaten the American people. Mexico needs to bolster supply chain integrity by soliciting greater private industry participation and significantly increasing inspections at its ports of entry. Additionally, Mexico’s current investments in its security forces are insufficient to sustain and expand its campaigns against narcoterrorists, their finances, and their criminal networks. This includes exposing, arresting, and prosecuting the many corrupt public officials that have aided and abetted the cartels and betrayed their own country’s security and sovereignty.
The drug threat to America extends beyond our northern and southern borders. The PRC continues to be the world’s largest producer of many of the precursor chemicals used to illicitly produce fentanyl, methamphetamine, and other deadly synthetic drugs. I have raised this directly with State Chairman Xi Jinping, and last year, at my request, the PRC implemented new requirements for its companies to obtain licenses before exporting designated precursor chemicals to North America. However, criminals continue to find ways around these controls through the use of unregulated precursor chemicals. The PRC needs to take more aggressive action to effectively reduce the flow of these substances by scheduling additional chemical precursors and substances requested by the United States. This enhanced cooperation will enable timely prosecution of the criminals responsible for supplying drug traffickers with deadly precursor chemicals.
Other governments have taken measures to confront drug trafficking and narcoterrorism. Dramatic political changes in South America over the past year have created historic openings for United States cooperation with governments in the region. In Venezuela, thanks to my Administration’s arrest and removal of former illegitimate dictator and drug trafficker Nicolás Maduro, we are already seeing the results of growing cooperation with the country’s interim government against cartels, including the elimination of Tren de Aragua leader Niño Guerrero. Given the positive steps taken under interim President Delcy Rodríguez, I have determined Venezuela should no longer be designated as having failed demonstrably to fulfill its drug control commitments. I expect to see continued, measurable progress from the interim government in dismantling narcoterrorist groups and stopping drug trafficking through Venezuela to the United States.
After decades of inept socialist governments, the United States welcomed the Bolivian people’s democratic choice in the 2025 elections and the opportunity to open a new chapter in United States-Bolivia relations under President Rodrigo Paz. Cooperation between Bolivia and the United States has significantly expanded over the last year, and I welcome the resumption of law enforcement coordination between our governments to target illicit drug production and criminal networks. Bolivia’s extradition of narcoterrorist Sebastián Marset to the United States in March 2026 highlighted our growing friendship and cooperation and prevented one of our hemisphere’s most notorious drug traffickers from shipping more drugs to American communities. However, the new government has not yet had sufficient time to reduce coca cultivation that increased under the previous government. Corruption in Bolivia continues to facilitate drug trafficking and impede investigations. If Bolivia can demonstrate progress in reducing illicit drug production in the coming year, and make substantive progress in tackling the endemic corruption weakening Bolivia, I will consider revisiting its status as having failed demonstrably to uphold its counterdrug commitments.
The people of Colombia made the courageous choice to elect Abelardo de la Espriella as President. He has pledged to lead an aggressive campaign against coca cultivation and cocaine production, which reached record levels under the failed socialist policies of his predecessor. Colombia is poised to resume its place as our foremost security partner in the hemisphere, and the country’s military, police, prosecutors, and courts now finally have a worthy champion in President de la Espriella. If, as expected, Colombia makes progress on aggressive coca eradication and dismantling its narcoterrorist networks over the coming year, I will consider lifting the country’s “failed demonstrably” status, which remains in place solely due to the incompetence and chaos produced by the previous far-left government in office throughout the bulk of the past year.
I welcome Prime Minister Modi and the Government of India’s efforts to address illicit opium poppy cultivation and bolster supply chain integrity. I look forward to continued cooperation through the United States-India Drug Policy Framework. In Peru, I likewise welcome the commitment of new President Keiko Fujimori to work with the United States and other allies to destroy the criminals ailing Peru and reduce cocaine flows bound for the United States. I also applaud three of America’s greatest allies in our hemisphere – Argentina, Ecuador, and El Salvador – for their leadership, resolve, and success in the fight against narcoterrorism.
While many governments in the Western Hemisphere are taking courageous action to reduce drug flows and eradicate cartels, the Government of Brazil has failed to confront the designated foreign terrorist organizations Primeiro Comando da Capital and Comando Vermelho,which have transformed Brazil into a hub for global cocaine flows. These Brazilian terrorist organizations are a growing threat to peace and security around the world, and Brazil’s government urgently must take aggressive measures to confront and defeat them before they spread and grow. Unsurprisingly, for a socialist dictatorship, the illegitimate Ortego-Murillo regime in Nicaragua has failed to take sufficient action against drug trafficking and the complicity of regime actors in the drug trade.
In Burma, the military regime has made little discernible effort to crack down on its drug economy, making the country the world’s largest source of opium poppy and one of the largest suppliers of methamphetamine. Despite the Taliban’s announced opium poppy ban, Afghanistan continues to supply drug markets across the world, likely funding Islamist terrorism. For these reasons, I am again determining that Burma and Afghanistan have failed demonstrably to uphold their drug control obligations.
You are authorized and directed to submit this determination, with the accompanying memoranda of justification, under Section 706 of the FRAA, to the Congress, and to publish this determination in the Federal Register.
As stated in President Trump’s Executive Order (EO) 14204, “Addressing Egregious Actions of the Republic of South Africa,” the United States remains gravely concerned about racially motivated crime and government-sponsored discrimination occurring against the Afrikaners and other minority populations in South Africa, including race-based discriminatory legislation, threats of land expropriation without compensation, and incitement of racial violence through dehumanizing chants and slogans.
The South African government has not adequately addressed the previously laid out concerns and so today, I am announcing a new visa restriction policy under Section 212(a)(3)(C) of the Immigration and Nationality Act targeting foreign nationals who are responsible for, or complicit in, the enactment or implementation of laws or policies that enable uncompensated land seizures, race-based discrimination, and/or the incitement of imminent violence against members of minority ethnic or racial groups in South Africa. The United States will not allow such behavior to go unchecked. These actions directly undermine peace, economic stability, and the rule of law, and they are incompatible with the pillars of America’s foreign policy.
We once again strongly urge the South African government to quickly address these egregious actions.
This visa restriction policy is pursuant to Section 212(a)(3)(C) of the Immigration and Nationality Act, which authorizes the Secretary of State to render inadmissible any alien whose entry into the United States “would have potentially serious adverse foreign policy consequences for the United States.” Certain family members may also be covered by these restrictions.
So… other than publicity, and maybe some secondary sanctions exposure, what was the value, if any, of that update? VTB was already subject to an asset freeze, no? explain in language for the common public
Claude’s initial response, which I took issue with:
You’re right about the core of it. VTB’s money was already frozen. Nothing about how an American bank handles a VTB hit changed on Sunday. Blocked is blocked, and there is no such thing as more blocked. If the only audience were US institutions, this update would be paperwork.
The audience is not US institutions.
The new tag changes which rulebook foreign banks apply. Russia sanctions and Iran sanctions are not two flavors of the same thing to a bank in Dubai, Istanbul, Mumbai or Shanghai. The Russia rules that expose foreign banks to US penalties are discretionary. Treasury may act against a foreign bank that handles significant business for a sanctioned Russian entity, and in practice it has acted sparingly, often with a warning first. The Iran rules are older, partly written by Congress rather than the President, and carry mandatory triggers. Foreign bank boards have long memories about what happened to institutions that got caught on the wrong side of Iran sanctions in the 2010s, and the fines involved.
There is a second layer that has nothing to do with US law. Many non-US banks write their own internal policies so that any Iran connection is a hard stop, while Russia exposure gets a case-by-case review. Adding an Iran tag to VTB can therefore trip a stricter internal rule automatically at institutions that had been carefully doing limited Russia business. That is my read from how these policies are typically drafted, not something Treasury said.
The designation also outlives a Russia deal. This is the part I would put first if I were writing it for a general reader. There is real talk of the Ukraine war ending and of Russia sanctions being unwound as part of a settlement. If that happens, VTB’s Russia designations come off. The Iran designation would not, because it rests on different conduct under a different authority. Think of a condemned building. A second violation notice does not make it more condemned, but if the first notice is withdrawn, the second one still keeps the doors locked. Treasury has bought itself a lock that a Russia peace deal does not open.
And it puts the accusation on the public record. Until this week, a foreign bank could plausibly say it had no idea VTB was running correspondent accounts for sanctioned Iranian banks or moving frozen Iranian assets. Now that claim is on a US government page with VTB’s name on it. Nobody gets to be surprised anymore, and “we didn’t know” stops being available as a defense.
One smaller thing that matters to people who run screening systems. OFAC took 21 of VTB’s old names, things like plain “VNESHTORGBANK,” and moved them from “used to be called this” to “also called this.” Some screening setups treat former names as lower priority or filter them out. Those 21 names just came back to full strength, and no press release explains why.
So the honest summary is that this update does very little to VTB’s money and quite a lot to VTB’s remaining business relationships and to the government’s negotiating position. Which is roughly what you would expect from a campaign whose stated goal is isolation rather than seizure.
My follow-up:
well, if you were already defying the US Russia sanctions, how likely is it that this would change your behavior? Is it just because the President is more focused on Iran now than Russia? And would it really change the behavior of Chinese firms?
And the response:
Your first question mostly answers itself, and it exposes something soft in what I told you earlier.
Anyone still clearing business for VTB in September 2026 has already made peace with being outside the US financial system. That population is self-selected for indifference. Adding a tag to a party you were already willing to be caught dealing with is not a new deterrent, it is the same deterrent restated. The banks that could be moved by this are the ones with US correspondent accounts they still want to keep, and those banks mostly exited VTB in 2022. So the group sitting between “already gone” and “already defiant” is thin.
I also overstated one thing. I said the Iran rules carry mandatory triggers where the Russia ones are discretionary. That is true of the statutory Iran provisions, CISADA and IFCA and the NDAA correspondent-account section, but it is not true of what OFAC actually invoked here. Treasury’s own release says OFAC “can prohibit or impose strict conditions on” a foreign bank’s correspondent account. That is permissive language. The legal difference between the Russia exposure and the new Iran exposure is narrower than I made it sound. What is genuinely different is reputational, not statutory.
On whether this is about presidential attention, largely yes, and I would put it more bluntly than I did. Treasury is running an Iran campaign that needs visible targets while it is simultaneously negotiating over Russia. Hitting VTB under a Russia authority would cut across the negotiation. Hitting the same bank under an Iran authority produces the headline without disturbing that track. The choice of authority is doing diplomatic work as much as legal work. The durability point I raised stands, since an Iran designation survives a Russia settlement, but I should be clear that is a benefit to Treasury’s future position rather than a cost imposed on VTB today.
Chinese firms are the weakest part of the case. The large state banks pulled back from VTB years ago and have run conservative Iran policies since the last decade. Nothing here reaches them because they already left. The institutions that do handle sanctioned trade are small regional banks with no dollar business to lose, and the precedent for how that plays out is Bank of Kunlun, which the US designated in 2012 over Iran and which China then simply used as the designated channel. Cutting a bank off from a system it does not use is not much of a penalty. Add that a growing share of this trade settles in renminbi through CIPS, and the lever you are pulling is attached to nothing.
Where I think there is real value, and it is plumbing rather than deterrence, is that a designation under an Iran authority creates a predicate for designating the people who help VTB with its Iran business. Those orders generally include a materially-assisted prong, though I have not pulled the text of 13902 to confirm the specific wording. If that is right, the update is less a punishment of VTB than a hook for whoever gets named next.
so, maybe not Much Ado About Nothing, but more like Much Ado About Something Possibly in the Future…. meh.
Wednesday 14 October 2026 at the Leonardo Royal Hotel, Tower Bridge, London
Dear Subscriber,
We are pleased to announce that bookings for the 2026 Export Control and Sanctions Symposium are now open. Places are limited and expected to fill quickly.
The Symposium will take place on Wednesday 14 October 2026, 8.45am – 5pm, Leonardo Royal Hotel, Tower Bridge, London E1 8GP
Attendance is open to exporters and service providers of all sizes at a cost of £396 (Including VAT) per person. Please review the registration requirements below before booking your place.
In addition to the opening Plenary, there are now four workshop choices delivered by ECJU, OTSI and partner organisations, as well as some joint sessions.
The popular Knowledge Hub returns with an extended lunchtime session, providing direct access to representatives from across EC&S, wider government and trade associations who can answer your questions and offer practical guidance.
Please complete a separate registration for each delegate.
Due to anticipated high demand, registrations will initially be limited to two delegates per business unit/division. Large organisations may register delegates from separate business units or divisions. Consulting, freight forwarding and law firms are limited to one delegate per organisation.
To view the agenda and book your place, please visit:Booking Webpage
New FAQ added – Asset freeze exception: crediting interest or other earnings on a frozen account
OFSI has published a new FAQ (203) clarifying whether a relevant institution may credit interest or other earnings accruing on one frozen account into a separate frozen account held for the same designated person.
The FAQ explains that regulation 58(3) of the Russia Regulations, and equivalent provisions in other regimes including the counter-terrorism regimes, only permits a relevant institution to credit a frozen account with interest or other earnings due on that account. The exception only applies where the interest or other earnings are credited to the same account on which they accrue.
The FAQ also applies where a separate frozen account has been nominated to receive the interest or earnings. Relevant institutions should consider whether a licence is required before making such payments.
The FAQs respond to stakeholder queries and aims to support a consistent understanding of the regime, helping to reduce the risk of circumvention. We encourage insurers, financial institutions and maritime operators to review the guidance and ensure internal processes reflect these considerations.
and the FAQ:
Asset freeze exception: crediting interest or other earnings on a frozen account
203. Does regulation 58(3) of The Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”), and its equivalent in other regimes including the counter terrorism regimes permit a relevant institution to credit interest or other earnings accruing on one frozen account into a separate frozen account held for the same designated person?
No. OFSI considers that regulation 58(3) of the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”), and its equivalent in other regimes including the counter terrorism regimes only permits a relevant institution to credit a frozen account with interest or other earnings due on that account. The exception only applies where the interest or other earnings are credited to the same account on which they accrue.
This is the case even where the separate account has been nominated to receive the relevant interest or other earnings or has otherwise been identified as the receiving account of such earnings under the contractual or other arrangements governing the accounts.
Relevant institutions should consider whether a licence is required before making such payments.
1245. What activities are authorized by Venezuela General License (GL) 52C, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.”?
Answer
GL 52C authorizes, subject to its conditions and exclusions, transactions prohibited by Executive Orders (E.O.s) 13884 or 13850 with Petróleos de Venezuela, S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), by established U.S. entities. Transactions authorized by GL 52C include activities related to:
the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan oil or petroleum products of Venezuelan-origin oil and petroleum products;
the provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors;
entry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products sectors of Venezuela;
the formation of new joint ventures or other entities in Venezuela related to such activities; and
all transactions ordinarily incident and necessary to such activities, including the performance of commercial, legal, technical, safety, and environmental due diligence and assessments related to the foregoing.
GL 52C also authorizes individuals blocked pursuant to the Venezuela Sanctions Regulations (VSR) to execute and sign contracts authorized by GL 52C in their official capacity as officers, employees, or authorized representatives of PdVSA or PdVSA Entities.
Notably, GL 52C does not authorize transactions that would otherwise be prohibited by the VSR and associated Executive Orders, including E.O. 13808 and E.O. 13835, such as:
transactions related to bonds and debt issued by PdVSA and its subsidiaries, including settlement of such bonds and debt;
transactions involving equity interest in PdVSA and its subsidiaries, including the sale, transfer, assignment, or use as collateral of equity interests in PdVSA and its subsidiaries by the Government of Venezuela;
transactions involving the transfer of equity interest in PDV Holding, CITGO Holding, or CITGO Petroleum Corp.;
transactions to affect or alter the governance of PDV Holding, Inc., Citgo Holding, Inc., or CITGO Petroleum Corporation, including the appointment, removal, or replacement of any director, officer, or other corporate governance official; or
transactions involving any other individuals or entities on the List of Specially Designated Nationals and Blocked Persons.
GL 52C also does not authorize:
transactions that are not on commercially reasonable terms;
payment in gold or the use of debt swaps;
payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled by or in a joint venture with such persons;
transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
the unblocking of any property blocked pursuant to the VSR; or
