OFAC's September 28 Venezuela oil licenses open trade, not a free payment route

The United States issued three amended licenses for specified Venezuelan oil and petrochemical business on September 28, but it did not give every buyer a free choice of counterparty, insurer or payment channel. The Office of Foreign Assets Control's amended General Licenses 46E and 48D permit defined trade and supply work, subject to contract, payment and counterparty conditions; General License 49B permits negotiation of new investments only when performance is expressly contingent on separate OFAC authorization. These are permissions under the Venezuela Sanctions Regulations, not evidence that a shipment has moved or a project has been financed. [1][2][3][4]
GL 46E covers specified Venezue…
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