OFAC confirms non-U.S. persons do not face sanctions risk when engaging with Venezuela under specific general licenses

The United States government, through its Office of Foreign Assets Control (OFAC), has updated its Frequently Asked Questions (FAQs) regarding Venezuela Sanctions. In response to question 1247, “Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46B, 51A, and 52?” the office indicated that they do not.

The post, published today, states that "Generally, non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized under GLs 46B, 51A, or 52 — such as transacting with PdVSA or importing Venezuelan-origin oil, petrochemical products, or minerals, into a third country”

The full OFAC post is provided here

The OFAC further clarifies that “These conditions are designed to ensure that transactions involving PdVSA or Venezuelan-origin oil, petrochemical products, and minerals occur through legitimate and authorized channels, consistent with efforts to restore prosperity, safety, and security to Venezuela. Non-U.S. persons who continue to transact with PdVSA or import Venezuelan-origin oil, petrochemical products, and minerals, including gold, without complying with the above conditions risk being designated themselves, including for providing financial, material, or technological support to blocked persons, being responsible for or complicit in a transaction involving deceptive practices or corruption and the Government of Venezuela, or operating in the gold or oil sectors of the Venezuelan economy.”

This clarification suggests that Trinidad & Tobago, through the National Gas Company of Trinidad and Tobago (NGC), can engage with relevant parties to pursue the development of Venezuelan gas fields without the need for a specific OFAC license or being included in the Annex of GL 51A.

The Energy Chamber of Trinidad and Tobago welcomes this news. The Chamber encourages continued dialogue and the pursuit of cross-border resource development to bring natural gas into the T&T infrastructure for processing and further export as LNG, or for use as feedstock in the production of methanol and ammonia.