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On July 10, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued General License 40B, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela” (“GL 40B”).  GL 40B authorizes US persons to engage in transactions related to the exportation or reexportation, directly or indirectly, of liquefied petroleum gas (” LPG”) to Venezuela involving the Government of Venezuela (“GOV”), Petróleos de Venezuela, S.A. (” PdVSA”), any entity 50% or more owned by PdVSA, or any GOV entity blocked solely pursuant to Executive Order 13884

The scope of GL 40B changed slightly with this reissuance by continuing to authorize “transactions” but not “activities” related to exports/reexports of LPG to Venezuela.   It remains the case that GL 40B does not authorize payment-in-kind of petroleum or petroleum products or the involvement of other Specially Designated Nationals.  Transactions covered by GL 40B are now authorized through 12:01 a.m. eastern daylight time on July 10, 2024.  Our blog on the initial issuance of GL 40 can be found here.

On the same day, OFAC made public regulations to implement Executive Order 14078, “Bolstering Efforts To Bring Hostages and Wrongfully Detained United States Nationals Home.”  These regulations take effect on July 11, 2023, when they are published in the Federal Register.  The new regulations will be found at 31 CFR Part 526.  This set of regulations is not a skeletal version that OFAC plans to supplement at a later date.  Our blog on the first designations under Executive Order 14078 can be found here.

The author acknowledges the assistance of Ryan Orange with the preparation of this blog post.


Alexandre Lamy joined Baker McKenzie in 2009 and currently works in the Firm's International Trade Practice Group. He assists clients with sanctions and export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and he advises clients on corporate compliance matters. Alex contributes regularly to Baker McKenzie's Sanctions & Export Controls Update blog.
Since August 2021, Alex has been the co-chair of the ABA Section of International Law’s Export Controls & Economic Sanctions Committee. Prior to that appointment, he served on the steering group and as a Vice Chair of the Committee, starting back in August 2011. Alex has organized multiple events regarding recent developments in US trade sanctions and export controls for the Committee.
Alex was recognized in Who's Who Legal 2020 Edition of its Global Guide to Trade & Customs Lawyers as a "leading individual" in North America on International Sanctions and the publication reported that he "attracts applause for delivering 'a practical service which understands the needs of the business'. His 'ready availability to clients, thorough research and strong presentation skills' are further acclaimed." He was also recognized in the 2019 Edition of the same publication as being "much sought after by clients who praise his 'advice of the highest quality' and add, 'He is technically very good on OFAC sanctions issues and military/dual use export controls.'" Alex was named by Financier Worldwide in, “POWER PLAYERS: International Trade & Sanctions 2021 - Distinguished Advisers.

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