On November 17, 2020, the US Treasury Department’s Office of Foreign Asset Control (OFAC) amended General License (“GL”) 8F and re-issued it as General License 8G.  GL 8G extends the validity period of certain limited maintenance and wind-down transactions and activities involving Petróleos de Venezuela S.A. (“PdVSA”) until June 3, 2021.   Our blog posts describing previous amendments to the general license are available here, here, here, and here.

Specifically, GL 8G extends the validity period of the authorization for certain transactions and activities otherwise prohibited by Executive Order (“EO”) 13850 (as amended by EO 13857) or EO 13884 that are ordinarily incident and necessary to the limited maintenance of essential operations, contracts, or other agreements that are (i) for the safety or the preservation of assets in Venezuela, (ii) involve PdVSA or its 50%-or-more owned subsidiaries, and (iii) were in effect prior to July 26, 2019 for the following entities and their subsidiaries: Chevron Corporation; Halliburton; Schlumberger Limited; Baker Hughes; and Weatherford International (“Covered Entities”).  Importantly, GL 8G also extends the validity period of the authorization to wind-down PdVSA-related activities involving Covered Entities, effectively providing US companies an additional six months to exit the market.  The additional six months is likely a recognition by OFAC of the complexities in doing so.   Beyond the extension of the validity period, there were no further substantial changes to GL as there have been in previously amended versions.

The authors, Nicholas F. Coward and Meghan Hamilton, acknowledge the assistance of Ryan Orange for this blog post.