The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently announced the removal of 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. The notice issued by OFAC states that Nynas AB “has undertaken a corporate restructuring that has resulted in Nynas AB no longer being blocked pursuant to the Venezuela Sanctions Regulations (31 C.F.R. Part 591).” As a result, U.S. persons and companies do not require authorization from OFAC to engage in transactions with Nynas AB, provided that such activities do not involve other blocked persons.
OFAC also issued two new General Licenses— GL 3H, which authorizes transactions related to certain bonds, and GL 9G, which authorizes transactions related to certain securities. Effective May 12, 2020, GL 3H replaces and supersedes GL 3G, while GL 9G replaces and supersedes GL 9F. Companies which relied on GL 3G and/or GL 9F for transactions should now reference GL 3H and/or GL 9G.
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 the above-referenced GLs or the Venezuela sanctions in general, please contact Cortney Morgan or Grant Leach of our Export Controls & Economic Sanctions team.