General License No. 44 is a regulatory provision that authorizes specific transactions related to the oil and gas sector operations in Venezuela. It is designed to provide guidance on which transactions are permitted despite the restrictions imposed by the Venezuela Sanctions Regulations (VSR). Here are the key points of General License No. 44:
- Authorization of Transactions: General License No. 44 allows for the following transactions related to the oil or gas sector operations in Venezuela until April 18, 2024:
- The production, lifting, sale, and exportation of oil or gas from Venezuela, along with the provision of related goods and services.
- Payment of invoices for goods or services related to oil or gas sector operations in Venezuela.
- New investments in oil or gas sector operations in Venezuela.
- Delivery of oil and gas from Venezuela to creditors of the Government of Venezuela, including creditors of PDVSA Entities, for the purpose of debt repayment.
- Limitations on Authorization: There are certain limitations and exceptions to the authorization:
- The general license does not authorize transactions involving financial institutions that are blocked pursuant to Executive Order 13850, except for Banco Central de Venezuela and Banco de Venezuela SA Banco Universal.
- It does not permit the provision of goods or services to, or new investment in, entities located in Venezuela that are owned or controlled by, or have joint ventures with, entities located in the Russian Federation.
- It prohibits transactions related to new investments in oil or gas sector operations in Venezuela by individuals or entities located in the Russian Federation.
- Certain transactions prohibited by Executive Order 13808 and other executive orders (E.O. 13827 and E.O. 13835) are not authorized by this general license.
- The unblocking of any property that was previously blocked under the VSR is not allowed.
- Compliance with Other Federal Agencies: It's essential to note that this general license does not exempt individuals or entities from compliance with the requirements of other federal agencies, including the Department of Commerce's Bureau of Industry and Security.
Another relevant license to mention is General License No. 43, which authorizes transactions involving CVG Compania General de Mineria de Venezuela CA (Minerven) and entities in which Minerven owns a 50 percent or greater interest. This complements the regulation and provides additional options for certain transactions that would otherwise be prohibited.
If you have any further questions or concerns, please don't hesitate to reach out to our team. |