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The framework rests on OFAC's Venezuela program. General License 41 narrowly authorised Chevron's operations; its terms — and the conditions for renewal — define most of the legitimate space. 12
Outside a specific license, dealings in PdVSA-linked oil risk secondary sanctions exposure under the executive orders, with the blocking provisions reaching non-US persons. 3
The practical read: exposure turns on the live license posture, which OFAC has tightened and loosened with the political cycle — so any opinion has to cite the current license text and the most recent guidance, not last year's. 45
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