Marine Advisory: 08/2021 - Advisory on General License 40 Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquified Petroleum Gas to Venezuela
21 July 2021
Marine Advisory 08/2021
compliance
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MARINE ADVISORY: 08/2021
(This Marine Advisory supplements Marine Advisories 04/2019, 12/2019, 18/2020)
SUBJECT: Advisory on General License 40 Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquified Petroleum Gas to Venezuela
On July 12, 2021, the Office of Foreign Assets Control (“OFAC”) issued General License 40 authorizing all transactions and activities related to the exportation or reexportation of liquified petroleum gas to Venezuela, involving the Government of Venezuela, Petroleos de Venezuela, S.A. (“PdVSA”) or any entity in which PdVSA owns directly or indirectly, a 50 percent or greater interest, until July 8, 2022.
The scope of General License 40 is limited to the exportation or reexportation of liquified petroleum gas to Venezuela, and expressly prohibits transactions where liquified petroleum products will be received by the Government of Venezuela or PdVSA in exchange for products which are not authorized by General license.
Additionally, Frequently Asked Question 914 published by OFAC clarifies that non-U.S. persons will not risk exposure to the U.S. sanctions for engaging in activities or facilitating transactions or payments for such activities that are authorized to U.S. persons under General License 40.
Finally, Frequently Asked Question 915 provides a definition of “liquified petroleum gas” as used in General License 40. Any voyages involving export and reexport of products outside the scope of General License 40 may present sanction risks.
Point of Contact
For further information regarding the issuance of this Advisory, contact the Compliance Department at +1 (703) 790-3434 or email to compliance@liscr.com. If after business hours, please contact the Duty Officer at + 1 703 963 6216 or Dutyofficer@liscr.com.
