On March 24, 2025, the White House issued Executive Order 14245 (“EO 14245”) to implement potential tariffs for countries importing Venezuelan oil as well as a Fact Sheet that summarizes EO 14245 at a high level. On the same date, the US Treasury Department’s Office of Foreign Assets Control issued General License (“GL”) No. 41B extending the wind down period of certain transactions related to Chevron Corporation joint ventures (“JVs”) in Venezuela.
EO 14245
This Order threatens a tariff of 25% on all goods imported into the United States from any country that, on or after April 2, 2025, imports Venezuelan oil, whether directly from Venezuela or indirectly through third parties. This is the first time the US Government has threatened tariffs against countries engaging in transactions that are contrary to US foreign policy.
EO 14245 specifies that such duties will be supplemental to duties already imposed pursuant to the International Emergency Economic Powers Act, Section 232 of the Trade Expansion Act of 1962, Section 301 of the Trade Act of 1974, or any other authority. The 25% tariff shall expire one year after the last date on which the subject country imported Venezuelan oil, which is defined in EO 14245 as “crude oil or petroleum extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products.” The expiry date of duties may be earlier, however, if the US Secretary of State so determines.
GL No. 41B
Amended GL No. 41B permits transactions “ordinarily incident and necessary to the wind down of transactions” related to Chevron’s JVs in Venezuela, as previously authorized by GL No. 41 (which we covered in a previous blog post here), and extends this authorization from April 3, 2025 to May 27, 2025. GL No. 41B is largely identical to GL No. 41A (which we covered in a recent blog post here), and does not amend the scope of activities that remain prohibited. The amended authorization does include a new note that GL No. 41B does not authorize the expansion of Chevron JVs into new fields in Venezuela.