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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On November 24, 2021, the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) issued Venezuela-related&nbsp;<a href="https://home.treasury.gov/system/files/126/venezuela_gl8i.pdf" target="_blank" rel="noopener">General License 8I</a>, &ldquo;Authorizing Transactions Involving Petr&oacute;leos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities.&rdquo; This general license continues to authorize transactions and activities &ldquo;ordinarily incident and necessary to the limited maintenance of essential operations, contracts, or other agreements,&rdquo; that:
<ol>
<li>are for safety or the preservation of assets in Venezuela;</li>
<li>involve PdVSA or any entity in which PdVSA owns, directly or indirectly, a 50% or greater interest; and</li>
<li>were in effect prior to July 26, 2019, for the following entities and their subsidiaries:</li>
</ol>
<ul>
<li style="list-style-type: none">
<ul>
<li>Chevron Corporation</li>
<li>Halliburton</li>
<li>Schlumberger Limited</li>
<li>Baker Hughes, a GE Company</li>
<li>Weatherford International, Public Limited Company</li>
</ul>
</li>
</ul>
The term &ldquo;safety or the preservation of assets&rdquo; covers transactions and activities necessary &ldquo;to ensure the safety of personnel, or the integrity of operations and assets in Venezuela; participation in shareholder and board of directors meetings; making payments on third-party invoices for transactions and activities authorized&rdquo; under this general license (or prior to April 21, 2020, if such activity was authorized at that time) as well as &ldquo;payment of local taxes and purchase of utility services in Venezuela; and payment of salaries for employees and contractors in Venezuela.&rdquo; The general license authorizes such activities involving PdVSA and the other listed entities through 12:01 a.m. EST, June 1, 2021.
As with past extensions, General License 8I does not authorize any activities related to Venezuelan-origin petroleum or petroleum products; the provision of insurance for such products; the design, construction or work on wells or other facilities or infrastructure in Venezuela; contracting any additional personnel or services (except as required for safety); or the payment of any dividends to PdVSA. Further, this General License does not authorize transactions related to the export or re-export of diluents to Venezuela; the issuance of any loans to, or accrual of additional debt by, or subsidization of PdVSA; or any transactions prohibited by OFAC&rsquo;s Venezuela Sanctions Regulations (31 C.F.R. part 591) or with any blocked persons other than those identified in this General License.
General License 8I replaces and supersedes General License 8H.&nbsp;See also&nbsp;SmarTrade Update of&nbsp;<a href="https://www.thompsonhinesmartrade.com/2021/06/ofac-again-issues-venezuela-general-license-to-continue-authorization-of-limited-transactions-involving-pdvsa-and-winding-down-of-operations-for-certain-entities/">June 2, 2021</a>.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

International Trade

OFAC Again Extends Venezuela General License to Continue Authorization of Limited Transactions Involving PdVSA and Winding Down of Operations for Certain Entities