On March 4, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 41A, “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela.” (“GL 41A”).

Under this license, any existing Chevron joint ventures involving Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, must wind down its operations on or before 12:01 a.m. EDT on April 3, 2025, when GL 41A is scheduled to expire.

General License 41A replaces and supersedes General License 41 (“GL 41”), which was issued in November 2022 and allowed Chevron to operate in Venezuela and export Venezuelan oil.  The license amendment was also issued approximately a week after President Trump’s announcement, on February 26, 2025, that he was revoking Chevron’s license to conduct oil operations in Venezuela.

When GL 41 was issued, OFAC had also published guidance indicating that U.S. persons were authorized to provide goods and services for certain activities in connection with the Chevron joint ventures, and that non-U.S. persons generally would not risk U.S. sanctions exposure for facilitating transactions authorized by GL 41.  This guidance will now be withdrawn upon expiration of GL 41A.

In addition, GL 41A also explicitly does not authorize:

• The payment of any taxes or royalties to the Government of Venezuela;
• The payment of any dividends, including a dividend in kind, to PdVSA, or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest;
• The sale of petroleum or petroleum products produced by or through the Chevron JVs for the exportation to any jurisdiction other than the United States;
• Any transaction involving an entity located in Venezuela that is owned or controlled by an entity located in the Russian Federation

If you have any questions regarding the matters covered in this e-mail, please contact Bruce Paulsen (212) 574-1533, Brian Maloney (212) 574-1448, Carmella O’Hanlon (212) 574-1351, or your primary Seward & Kissel attorney.