The Office of Foreign Assets Control of the US Department of the Treasury has issued three amended general licenses allowing certain Venezuela-related transactions.
General License 15C, which replaces GL 15B, “Authorizing Transactions Involving Certain Banks for Certain Entities,” allows transactions otherwise prohibited by Executive Orders 13884, 13850 or 13857 that are ordinarily incident to the activities of MoneyGram International, Western Union Company, American Express Company, Visa Inc., or MasterCard Incorporated, and involve four named Venezuelan banks and their subsidiaries.
General License 16C replaces GL 16B, and authorizes activities that are ordinarily incident to maintaining, operating or closing accounts belonging to US persons in three specified banks and would otherwise be prohibited by Executive Orders 13850, 13857 or 13844. GL 16C also authorizes personal remittances involving the named banks.
General License 36A, “Authorizing Certain Activities Necessary to the Wind Down of Transactions Involving Rosneft Trading S.A. or TNK Trading International S.A.,” replaces GL 36, and extends the expiration of the authorizations provided therein until May 20, 2020. These include activities otherwise prohibited by Executive Order 13850 as amended by Executive Order 13857 that are ordinarily incident to the wind down of transactions with Rosneft or TNK Trading and subsidiaries thereof. OFAC published two amended Frequently Asked Questions in connection with General License 36A.
In a related action, OFAC designated TNK Trading International S.A., a Switzerland-incorporated company, pursuant to Executive Order 13850, as amended, for operating in the oil sector of the Venezuelan economy. TNK is a subsidiary of the Russian state-controlled Rosneft Oil Company, which was designated pursuant to Executive Order 13662 in 2014. According to OFAC, TNK has been involved in transporting petroleum products from Venezuela. Following the designation of TNK, US property of the company and its subsidiaries is blocked, and must be reported to OFAC.