Venezuelan Oil Sanctions: Structuring Energy Transactions Under OFAC General License No. 46

Seth will participate in a CLE panel examining OFAC General License 46 and the evolving U.S. sanctions framework governing Venezuelan-origin oil. The discussion will focus on structuring and documenting transactions to align with authorized activities while managing ongoing sanctions, export controls, banking requirements, and contractual risk. Panelists will review the sanctions timeline and market developments following issuance of GL 46, as well as the operational controls practitioners must implement, including screening protocols, payment governance, counterparty diligence, contractual contingencies, recordkeeping, and potential wind-down provisions if authorizations change. The panel will also address the scope of covered actors and conduct, multi-agency compliance challenges, and practical strategies for drafting and negotiating agreements, including representations, conditions precedent, termination and suspension rights, risk allocation, compliance covenants, and dispute-readiness considerations.

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