Our Circular of 8 December 2023 highlighted that the US had issued a six-month General License No.44 (“GL 44”), Authorizing Transactions Relating to Oil or Gas Sector Operations in Venezuela until 18 April 2024 (available here).GL44 has now been replaced and superseded by General License No.44A (“GL44A”). GL44A authorises the wind down of any transactions related to oil or gas sector operations in Venezuela that were authorised by GL44 by 31 May2024. As set out in the accompanying FAQs:Specifically, GL 44A authorizes all transactions that are ordinarily incident and necessary to the wind down of any transactions related to oil or gas sector operations in Venezuela that were previously authorized by Venezuela GL 44 by May 31, 2024. GL 44A authorizes the wind down of, among others, the following non-exhaustive list of transactions that were authorized by GL 44: (1) the production, lifting, sale, and exportation of oil or gas from Venezuela, and provision of related goods and services; (2) the payment of invoices for goods or services related to oil or gas sector operations in Venezuela; and (3) the delivery of oil and gas from Venezuela to creditors of the Government of Venezuela, including creditors of entities in which Petróleos de Venezuela, S.A. (PdVSA) owns, directly or indirectly, a 50 percent or greater interest, for the purpose of debt repayment. Entering into new business, including new investment, that was previously authorized under GL 44 will not be considered wind-down activity. U.S. persons unable to complete transactions previously authorized by GL 44 before 12:01 a.m. eastern daylight time, May 31, 2024, are encouraged to seek guidance from OFAC. Non-U.S. persons may wind down transactions or activity without exposure to sanctions, provided that such wind down activity is consistent with GL 44A. Non-U.S. persons unable to wind down such transactions or activity before 12:01 a.m. eastern daylight time, May 31, 2024, are encouraged to seek guidance from OFAC.