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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 January 30, 2024, the Department of State announced in a <a href="https://www.state.gov/venezuela-sanctions-actions-and-supporting-democracy/" target="_blank" rel="noreferrer noopener">press release</a> that the United States would be reinstating certain sanctions actions on Venezuela in light of recent activities by President Nicol&aacute;s Maduro and his regime, including the recent barring of opposition candidates from competing in Venezuela&rsquo;s 2024 presidential election.
In October 2023, the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) issued several new Venezuela-related General Licenses authorizing various transactions that would otherwise be prohibited under U.S. sanctions toward Venezuela. These earlier developments were in response to a political agreement between Maduro&rsquo;s representatives and the Unitary Platform that appeared to indicate a step forward in restoring democracy in Venezuela. At the time of relaxation of these U.S. sanctions, OFAC indicated they were conditional and could be rescinded if commitments were not met. See Thompson Hine Update of <a href="https://www.thompsonhine.com/insights/ofac-loosens-venezuelan-sanctions-authorizes-transactions-involving-oil-and-gas-state-owned-gold-mining-company-and-certain-debt-and-equity-of-venezuela-and-pdvsa/">October 24, 2023</a>, for additional details on the original relaxation of sanctions.
Given recent suppression of the democratic opposition in Venezuela, two OFAC-issued Venezuela General Licenses (GL) will be impacted:
<ul class="wp-block-list">
<li>Venezuela GL 43 authorized transactions involving CVG&nbsp;Compania General de Mineria de Venezuela CA, the Venezuelan state-owned gold mining company. This GL is revoked as of February 13, 2024, and U.S. persons have 14 days to wind down any transactions that were previously authorized by this GL.</li>
<li>Venezuela GL 44 temporarily authorized all transactions that are related to the oil and gas sector operations in Venezuela that would otherwise be prohibited under the Venezuelan Sanctions Regulations. According to the State Department&rsquo;s press release, &ldquo;Absent progress between Maduro and his representatives and the opposition Unitary Platform, particularly on allowing all presidential candidates to compete in this year&rsquo;s election,&rdquo; this GL will not be renewed when it expires on April 18, 2024. </li>
</ul>
It is assumed that at a later date, OFAC will revise its Venezuela FAQs to address the resumption of these sanctions. All other sanctions on Venezuela remain in effect.

United States to Reinstate Certain Sanctions on Venezuela

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