On July 12, 2021, the Department of the Treasury’s Office of Foreign Assets Control issued General License 40, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela,” pursuant to Venezuela Sanctions Regulations 31 CFR Part 591. OFAC also issued Frequently Asked Questions 914 and 915 to clarify the provisions in the license.
GL 40 temporarily authorizes transactions that directly or indirectly relate to the exportation or reexportation of liquefied petroleum gas to Venezuela that involves the Government of Venezuela, the Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns at least a 50 percent interest, that were otherwise prohibited by Executive Order 13850 of November 1, 20218, as amended by EO 13857 of January 25, 2019, or EO 13884 of August 5, 2019. These transactions are authorized until July 8, 2022.
According to FAQ 914, non-US persons who engage in activities described in GL 40 do not risk exposure to US sanctions if they are engaging in transactions or activities that are authorized for US persons. FAQ 915 provides a formal definition of liquefied petroleum gas with a discussion of the definition as provided by the US Energy Information Administration.