Lawyers: Industry Starting to Move Forward with Venezuela Deals
International Trade attorney Stephanie Connor and Financial Services attorney Andres Fernandez were quoted in an Export Compliance Daily article on growing industry confidence in processing transactions involving Venezuela's oil and gas sector following U.S. sanctions relief and the issuance of multiple general licenses by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC).
Ms. Connor said companies should carefully evaluate whether their transactions are already authorized under an existing general license before seeking specific approval from OFAC, noting that the agency is inundated with requests.
"They've published these general licenses for a reason, and they really don't like to see requests for activities that are already authorized," she explained.
Mr. Fernandez added that banks and other financial institutions are becoming more open to handling Venezuela-related transactions, but only when supported by robust documentation and due diligence confirming that the activity falls within the scope of the applicable license.
"We're seeing the banks getting comfortable with processing this activity, but they do want to see invoices, they do want to see bills of lading, they do want to see agreements," he observed.
READ: Lawyers: Industry Starting to Move Forward with Venezuela Deals (Subscription required)