About the Course
Introduction
This CLE webinar will examine the evolving U.S. regulatory framework for Venezuelan-origin oil and recent changes to the OFAC licenses for doing business in Venezuela. The panel will discuss structuring and documenting transactions to fit within authorized activity while managing remaining sanctions, export controls, banking regulatory hurdles, and contractual risk.
Description
The panel will discuss the evolving Venezuelan commerce opportunities amid shifting sanction policy and the new market context under recent Trump administration actions and licensures. Practitioners advising on cross-border energy transactions must interpret the license text to create operational controls, including screening protocols, payment-channel governance, counterparty diligence, contract contingencies, records management, and wind-down language if authorizations change again. The panel will address the scope of covered actors and conduct as well as the complexity of multi-agency compliance that can derail commercial deals.
Listen as our panel discusses practical approaches for drafting and negotiating agreements, with consideration of best practices for representations, conditions precedent, termination and suspension rights, risk allocation, compliance covenants, and dispute-readiness measures for Venezuelan-origin oil and related transactions under OFAC's licensures.
Presented By
Mr. Racco advises clients on a wide range of international trade regulations, including sanctions and export controls under the Export Administration Regulations, Foreign Trade Regulations, International Traffic in Arms Regulations), and Office of Foreign Assets Control regulations. He also routinely counsels clients on the Committee on Foreign Investment in the United States (CFIUS) regulations, anti-boycott laws, Withhold Release Orders, and anti-corruption laws including the Foreign Corrupt Practices Act. Mr. Racco provides clients with a variety of trade compliance services, such as: transaction-related due diligence; counseling on, and the preparation of, filings to CFIUS; determining the export classifications of products; advising on and preparing export license applications; providing advice and counsel on a wide range of sanctions questions; complying with, and challenging WROs and findings of forced labor by Customs and Border Protection; delivering compliance training; and helping clients design and implement tailored international trade compliance policies and procedures. In addition, he has conducted hundreds of internal investigations related to potential violations of international trade compliance regulations and has extensive experience drafting voluntary disclosures to relevant agencies.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Thursday, April 30, 2026
- schedule
1:00 p.m. ET/10:00 a.m. PT
I. Sanction policy shifts: Timeline, market context
II. Scope of the GL's, limits and related licenses: covered actors, covered conduct, interpretation
III. Structuring energy transactions under OFAC licensures
IV. U.S. regulatory compliance, interagency overlap, operational constraints
V. Disputes, enforcement, and wind-down preparedness
VI. Practitioner takeaways
The panel will explore these and other key areas:
- Identifying what changed in practical terms for energy commerce in Venezuela.
- Distinguishing covered actors and covered conduct under the GL's
- Drafting and negotiating core contract protections
- Coordinating OFAC analysis with related U.S. regulatory touchpoints
- Anticipating enforcement and private dispute exposure
- Building wind-down preparedness into agreements
