U.S. Reimposes Venezuela Sanctions Following Actions by Maduro Government

Washington, D.C. (February 6, 2024) - On January 30, 2024, the United States took steps to reimpose sanctions on Venezuela, following actions by the Maduro government deemed by the U.S. Department of State to be inconsistent with prior agreements. These steps include retracting general licenses and an indication that further sanction-related action may be taken, should such actions by the Maduro government continue.

In a press statement, the U.S. Department of State indicated that certain general licenses issued in October 2023 (see our prior alert, "U.S. Suspends Select Venezuela Sanctions Following Political Agreement") would be revoked or otherwise not renewed upon expiration. Specifically, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) revoked General License 43, which previously authorized transactions with CVG Compania General de Mineria de Venezuela CA (Minerven), a Venezuelan state-run ferrous metals mining company. In its place, OFAC issued General License 43A, giving U.S. companies until 12:01 a.m. EST, February 13, 2024, to wind down previously authorized transactions with Minerven.

The State Department’s press statement further indicated that, “[a]bsent progress between Maduro and his representatives and the opposition Unitary Platform, particularly on allowing all presidential candidates to compete in this year’s election,” General License 44 will not be renewed when it expires on April 18, 2024. That general license broadly authorizes transactions in the Venezuelan oil and gas sector, including, but not limited to: (1) the production, lifting, sale, and exportation of oil or gas from Venezuela, and provision of related goods and services; (2) payment of invoices for goods or services related to oil or gas sector operations in Venezuela; (3) new investment in oil or gas sector operations in Venezuela; and (4) delivery of oil and gas from Venezuela to creditors of the government of Venezuela, including creditors of Petróleos de Venezuela S.A. (PdVSA) Entities, for the purpose of debt repayment.

Should the general license expire without renewal, such transactions will no longer be authorized, absent a specific license granted on a case-by-case basis by OFAC.

Lewis Brisbois’ experienced attorneys are helping clients navigate rapidly developing, sanction-related legal and business risks. For more information on these developments, contact the authors of this alert. Visit our Ukraine Conflict Response Practice page for more information about our capabilities and for similar alerts in this area.