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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 July 12, 2021, the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) issued&nbsp;<a href="https://home.treasury.gov/system/files/126/venezuela_gl40.pdf">Venezuela-related General License 40</a>, &ldquo;Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.&rdquo; &nbsp;This general license authorizes all transactions and activities related to the exportation or reexportation, directly or indirectly, of liquefied petroleum (LP) gas to Venezuela, involving: (i) the Government of Venezuela, (ii) Petr&oacute;leos de Venezuela, S.A. (PdVSA), or (iii) any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater&nbsp;interest, that are prohibited by <a href="https://home.treasury.gov/system/files/126/venezuela_eo_13850.pdf">E.O. 13850</a>, as amended by <a href="https://home.treasury.gov/system/files/126/13857.pdf">E.O. 13857</a>, or <a href="https://home.treasury.gov/system/files/126/13884_0.pdf">E.O. 13884</a>.&nbsp; The general license is effective through &nbsp;July 8, 2022.
OFAC has made clear that for its purposes, the term LP gas means &ndash; &ldquo;a group of hydrocarbon gases, primarily propane, normal butane, and isobutane, derived from crude oil refining or natural gas processing. These gases may be marketed individually or mixed. They can be liquefied through pressurization (without requiring cryogenic refrigeration) for convenience of transportation or storage. The definition excludes ethane and olefins.&rdquo;
General License 40 does not authorize any payment-in-kind of petroleum or petroleum products, and continues to prohibit any other activities otherwise prohibited by OFAC&rsquo;s Venezuela Sanctions Regulations.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

International Trade

OFAC Issues General License 40 Authorizing Certain Transactions Involving the Export of LP Gas to Venezuela