The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently issued General License 13E (“GL 13E”), authorizing certain activities involving Nynas AB, a Swedish manufacturer of specialty oils owned in part by PDVSA, Venezuela’s state-owned oil company, which would normally be prohibited by Executive Order 13850 (“E.O. 13850”).  The notice issued by OFAC indicates that Nynas AB “is engaged with OFAC on a proposed corporate restructuring that could potentially result in significant changes to Nynas AB’s ownership and control.”  As a result, the general license is being extended until May 14, 2020 to allow Nynas AB additional time to “complete the engagement.”

Effective April 3, 2020, GL 13E replaces and supersedes GL 13D by extending certain authorized transactions through May 14, 2020 where the only Government of Venezuela entities involved are Nynas AB or any of its subsidiaries.  Companies which relied on GL 13D for transactions should now reference GL 13E. OFAC notes that GL 13E does not authorize the following:

  • Any exportation or reexportation of any goods, services, or technology, directly or indirectly, by U.S. persons wherever located or from the United States to the Government of Venezuela, other than to Nynas AB or any of its subsidiaries;
  • Any transactions or dealings related to the exportation or reexportation of diluents, directly or indirectly, to Venezuela;
  • Any transactions or dealings related to the purchase or acquisition of Venezuelan-origin petroleum or petroleum products, directly or indirectly, by Nynas AB or any of its subsidiaries; and
  • Any transactions or activities otherwise prohibited by the Venezuelan Sanctions Regulations, or any other part of 31 C.F.R. Chapter V.

Husch Blackwell continues to monitor the U.S. sanctions on Venezuela and will provide updates as more information becomes available.  Should your company have any questions regarding GL 13E or the Venezuela sanctions in general, please contact Cortney Morgan or Grant Leach of our Export Controls & Economic Sanctions team.