OFAC licenses in Venezuela: contracts with PDVSA no longer need U.S. governing law
The requirement arrived in January, loosened in June and vanishes today from eight licenses at once. What did not move in those seven months: the seat of disputes, the routing of payments through the Treasury, and the same six oil companies cleared to operate.
Two lines required a contract signed in Caracas to be read under U.S. law. As of this morning they are gone from all eight licenses that carried them. The other half of the clause survives: the one setting where the fight happens if the deal breaks.
All eight were signed this morning and cover oil, diluents, services to the energy sector, operations of the annexed oil companies, gold, transactions with the state firm, mining services and telecommunications. Where June's text required that "the terms of the contract be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States," there is now nothing. Disputes must still be resolved in the United States, the United Kingdom, France or Singapore.
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