April 21, 2020

On April 21, 2020, OFAC issued General License (GL) 8F, which authorizes a more limited scope of activities and transactions that Chevron, Halliburton, Schlumberger, Baker Hughes, and Weatherford may engage in with PdVSA in Venezuela. GL 8F provides that the covered entities may engage in transactions and activities incident and necessary to a limited maintenance of essential operations, contracts, or other agreements, that: “(i) are for the safety or the preservation of assets in Venezuela; (ii) involve PdVSA or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest; and (iii) were in effect prior to July 26, 2019.”  This new GL is notable in that it no longer covers a number of other activities that were authorized by previous iterations of the original GL 8, including design and construction of wells; drilling and processing of Venezuelan-origin petroleum and petroleum products; and contracts for additional personnel or services, except as required for safety.  Any company that supplies or otherwise transacts with the covered entities in Venezuela should immediately review this more limited GL to determine whether its activities would continue to be authorized, and if not, determine any necessary steps that need to be taken to ensure compliance with OFAC’s sanctions. This General License expires on December 1, 2020.

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