Sanctions - Venezuela

Timeline of Key Events: January – September 2026

The following table summarises the principal US measures since the seizure of Nicolas Maduro and the initial issuance of the 2026 General Licences:

General Licence 46D: Venezuelan-Origin Oil or Petrochemical Products 

Overview

GL 46 was originally issued on 29 January 2026 and has been amended three times since. GL 46D, issued on 27 August 2026, replaces and supersedes GL 46C in its entirety. It remains the primary authorisation enabling the lifting and trade of Venezuelan oil and petrochemical products.

GL 46D authorises all transactions prohibited by the Venezuela Sanctions Regulations ("VSR") that are ordinarily incident and necessary to the lifting, exportation, re-exportation, sale, resale, supply, storage, marketing, purchase, delivery or transportation of Venezuelan-origin oil, including the refining of such oil, or of Venezuelan-origin petrochemical products for importation into the United States, by an established US entity.

The scope distinction between the two commodity categories continues to matter. The oil authorisation extends to trade with any destination, subject to reporting. The petrochemical products authorisation is limited to importation into the United States.

Who can use GL 46D – "Established US Entity"

Only an " established US entity " may rely on GL 46D to transact directly with PdVSA or the Government of Venezuela. The term means any entity organised under the laws of the United States or any jurisdiction within the United States on or before 29 January 2025.

Non-US persons may engage in transactions ordinarily incident and necessary to the established US entity's authorised activities. Note 2 to paragraph (a) of GL 46D expressly confirms that authorised transactions include arranging shipping and logistics services, chartering vessels, obtaining marine insurance and P&I coverage, and arranging port and terminal services, including with port authorities or terminal operators forming part of the Government of Venezuela.

Key conditions

• Dispute resolution forum: any contract for authorised transactions with the Government of Venezuela, PdVSA or PdVSA Entities must require that dispute resolution proceedings relating to the contract occur in the United States, the United Kingdom, France or Singapore. There is no longer any requirement as to governing law. The condition applies only to the direct contract with the Venezuelan state counterparty and does not flow down to shipowners, insurers or other indirect counterparties ( FAQ 1233).
• Payment into Foreign Government Deposit Funds: any monetary payment to a blocked person, excluding payments for local taxes, permits or fees, must be made into the Foreign Government Deposit Funds established under EO 14373, or into such other account as the US Treasury directs.

Petrochemical products

Note 3 to paragraph (a) confirms that "petrochemical products" includes fertilizer products and fertilizer precursor chemicals. GL 46D carries an Annex listing the relevant chemicals by name and HS code, running from sulphur and phosphate rock through ammonia, urea and the ammonium and potassium fertilizer families. Members carrying fertilizer or fertilizer precursor cargoes of Venezuelan origin should check the cargo description against the Annex.

What GL 46D does not authorise

• Payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are denominated in digital currency, digital coin or digital tokens issued by, for or on behalf of the Government of Venezuela, including the petro;
• Any transaction involving a person located in or organised under the laws of Russia, Iran, North Korea or Cuba, or any entity owned or controlled, directly or indirectly, by or in a joint venture with such persons;
• Any transaction involving an entity located in or organised under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organised under the laws of China. This does not prevent an established US entity from reselling Venezuelan oil to China;
• The unblocking of any property blocked under the VSR; or
• Any transaction involving a blocked vessel.

GL 46D does not authorise exploration activity or negotiations for new investment. GL 49A addresses contingent contracts for new investment.

Mandatory reporting

Any person that exports, re-exports, sells, resells or supplies Venezuelan-origin oil to countries other than the United States under GL 46D must report to Sanctions_inbox@state.gov and VZReporting@doe.gov, identifying the parties, the quantities, values and countries of ultimate destination, the dates of the transactions, and any taxes, fees or other payments provided to the Government of Venezuela. The first report is due ten days after execution of the first such transaction, and every 90 days thereafter while transactions are ongoing.

GeneralLicence 47B: Sale of US-Origin Diluents to Venezuela 

GL 47B, issued on 27 August 2026, replaces GL 47A in its entirety. It authorises transactions involving the Government of Venezuela and/or PdVSA that are ordinarily incident and necessary to the exportation, re-exportation, sale, resale, supply, storage, marketing, delivery or transportation of US-origin diluents to Venezuela. OFAC has not defined "US-origin diluents".

Authorised transactions include processing of payments, arranging shipping and logistics services including chartering vessels, obtaining marine insurance and P&I coverage, and arranging port and terminal services, including with Venezuelan government port authorities or terminal operators.

The only condition attached to paragraph (a) is the dispute resolution forum requirement. Unlike GL 46D, GL 47B does not impose a Foreign Government Deposit Funds payment condition.

GL 47B does not authorise non-commercially reasonable payment terms, debt swaps, gold payments or transactions denominated in Venezuelan-issued digital currencies; transactions involving persons located in or organised under the laws of Iran, North Korea or Cuba, or entities owned or controlled by or in a joint venture with such persons; the unblocking of blocked property except as provided in paragraph (a); or transactions involving a blocked vessel.

GL 47B remains the outlier in the family: it contains no Russia restriction and no China restriction.

Reporting is to Sanctions_inbox@state.gov and VZReporting@doe.gov, identifying the parties, the quantities and values, and the dates of the transactions, within ten days of the first transaction and every 90 days thereafter.

GeneralLicence 48C: Supply of Certain Items and Services to Venezuela 

GL 48C, issued on 27 August 2026, replaces GL 48B in its entirety. It authorises transactions ordinarily incident and necessary to the provision, from the United States or by a US person, of goods, technology, software or services for:

• the exploration, development or production of oil, gas or petrochemical products in Venezuela; or
• the generation, transmission, storage or distribution of electricity in Venezuela.

Authorised transactions include processing of payments, arranging shipping and logistics services including chartering vessels, obtaining marine insurance and P&I coverage, and arranging port and terminal services. Maintenance of oil, gas, petrochemical and electricity operations is covered, including refurbishment or repair of the items used in those activities. As with GL 46D, "petrochemical products" includes fertilizer products and precursor chemicals, and GL 48C carries the same Annex.

Both the dispute resolution forum condition and the Foreign Government Deposit Funds payment condition apply.

GL 48C does not authorise non-commercially reasonable payment terms, debt swaps, gold payments or Venezuelan digital currencies; transactions involving persons located in or organised under the laws of Russia, Iran, North Korea, Cuba or China, or entities owned or controlled by or in a joint venture with such persons; the unblocking of blocked property; transactions involving a blocked vessel; the formation of new joint ventures or other entities in Venezuela to explore or produce oil, gas or petrochemical products or to generate, transmit, store or distribute electricity; or any transaction related to the exportation or re-exportation of diluents to Venezuela, which remains the province of GL 47B.

Reporting is to Sanctions_inbox@state.gov and VZReporting@doe.gov within ten days of the first transaction and every 90 days thereafter, identifying the parties, the goods, technology, software or services involved including quantities and values, the dates, and any payments to the Government of Venezuela.

General Licence 50C: Oil and Gas Operations ofNamed Entities 

GL 50C, issued on 27 August 2026, replaces GL 50B in its entirety. It authorises transactions related to oil or gas sector operations in Venezuela of the entities listed in its Annex and their subsidiaries. The Annex as at 27 August 2026 lists six entities, unchanged from earlier versions:

• BP PLC
• Chevron Corporation
• Eni S.p.A.
• Établissements Maurel & Prom SA
• Repsol S.A.
• Shell PLC

GL 50C provides broader authorisation than GL 46D, which is confined to the trade of oil already extracted, and than GL 48C, which covers the supply of goods and services.

Both the dispute resolution forum condition and the Foreign Government Deposit Funds condition apply. Note 1 to paragraph (a)(2) specifically requires that payments of oil or gas taxes or royalties to the Government of Venezuela, PdVSA or any PdVSA Entity be paid into the Foreign Government Deposit Funds or as otherwise instructed by Treasury.

GL 50C does not authorise non-commercially reasonable payment terms, debt swaps, gold payments or Venezuelan digital currencies; transactions involving a person located in Russia, Iran, North Korea, Cuba or China, or any entity owned or controlled by or in a joint venture with such persons; the unblocking of blocked property; or transactions involving a blocked vessel.

Reporting is to Sanctions_inbox@state.gov and VZReporting@doe.gov within ten days of the first transaction and every 90 days thereafter.

General Licence 51D: Venezuelan-Origin Coal or Minerals, Including Gold

GL 51D, issued on 2 September 2026, replaces GL 51C in its entirety. It authorises transactions prohibited by the VSR, including those involving the Government of Venezuela, Carbones del Zulia S.A. (“Carbozulia”), CVG Compañía General de Minería de Venezuela CA (“Minerven”) or any entity in which Minerven owns 50 per cent or more (“Minerven Entities”), that are ordinarily incident and necessary to the exportation, re-exportation, sale, resale, supply, storage, purchase, delivery or transportation of Venezuelan-origin coal or minerals, including gold, by an established US entity.

As with GL 46D, only an established US entity — one organised under US law on or before 29 January 2025 — may rely on the licence to transact directly with the Venezuelan state counterparty.

Carbozulia is named as part of the Government of Venezuela, but it is not brought within the definition of “Minerven Entities”. The 50 per cent ownership test in that definition attaches to Minerven alone. A company in the Carbozulia group is therefore not automatically covered by the defined term, and its status should be checked separately.

Authorised transactions include commercial, legal, technical, safety and environmental due diligence and assessments; arranging shipping and logistics services including chartering vessels; arranging security services; obtaining marine insurance and P&I coverage; and arranging port and terminal services, including with Venezuelan government port authorities or terminal operators. Processing and refining of the coal or minerals is authorised, subject to the exclusions below.

Both the dispute resolution forum condition and the Foreign Government Deposit Funds condition apply.

GL 51D does not authorise:

• Payment terms that are not commercially reasonable, involve debt swaps or in-kind payments, or are denominated in Venezuelan-issued digital currencies;
• Transactions involving persons located in or organised under the laws of Russia, Iran, North Korea or Cuba, or entities owned or controlled by or in a joint venture with such persons;
• Transactions involving an entity located in or organised under the laws of Venezuela or the United States that is owned or controlled by or in a joint venture with a Chinese person;
• The processing or refining of Venezuelan-origin coal or minerals, including gold, in Russia, Iran, North Korea, Cuba or China;
• The unblocking of blocked property;
• Transactions involving a blocked vessel; or
• Exploration, development, mining, extraction, processing, refining or production of coal or minerals in Venezuela, or the formation of joint ventures or other entities in Venezuela to engage in those activities. Upstream coal and minerals activity in Venezuela is instead addressed by GL 54C and, as to contingent investment contracts, GL 55A.

Reporting under GL 51D is more demanding than under the oil licences. Reports go to Sanctions_inbox@state.gov and ofac_intake@doi.gov (Department of the Interior, not Energy), and must identify the parties, documentation demonstrating supply chain due diligence plans to determine the chain of custody of the coal or minerals, quantities, descriptions and purchase prices, the dates, and any payments to the Government of Venezuela. The first report is due ten days after the first transaction and every 30 days thereafter, not every 90.

General Licence 52B: Certain Transactions Involving PdVSA

GL 52B, issued on 27 August 2026, replaces GL 52A in its entirety. It is the broadest of the PdVSA-facing licences: it authorises all transactions prohibited by EO 13884 or EO 13850 involving PdVSA or PdVSA Entities by an established US entity, together with transactions involving the Government of Venezuela otherwise prohibited by EO 13884 that are necessary for those activities.

Both the dispute resolution forum condition and the Foreign Government Deposit Funds condition apply.

The exclusions are extensive, and are the practically important part of the licence. GL 52B does not authorise:

• Transactions otherwise prohibited by the VSR, including transactions prohibited by EO 13808 relating to bonds and certain other debt of the Government of Venezuela or PdVSA, including transactions to settle such bonds and debt, and transactions prohibited by EO 13835 relating to the sale, transfer, assignment or pledging as collateral of equity interests in PdVSA, PdVSA Entities or other entities in which the Government of Venezuela holds 50 per cent or more;
• Entry into a settlement agreement, or the enforcement of any lien, judgment, arbitral award, decree or other order through execution, garnishment or other judicial process, purporting to transfer or otherwise alter or affect property or interests in property of any person blocked under the VSR, including PdVSA or a PdVSA Entity. Members holding awards or judgments against PdVSA interests should note that enforcement remains unauthorised;
• Any transaction involving an individual or entity on the SDN List other than PdVSA itself, or any entity 50 per cent or more owned by such persons other than PdVSA Entities;
• Non-commercially reasonable payment terms, debt swaps, gold payments or Venezuelan digital currencies;
• Transactions involving persons located in or organised under the laws of Russia, Iran, North Korea or Cuba, or entities owned or controlled by or in a joint venture with such persons;
• Transactions involving a Venezuelan or US entity owned or controlled by or in a joint venture with a Chinese person;
• The unblocking of blocked property; or
• Transactions involving a blocked vessel.

Reporting under GL 52B is triggered by the export, re-export, sale, resale or supply of Venezuelan-origin oil or Venezuelan-origin petrochemical products to countries other than the United States, and goes to Sanctions_inbox@state.gov and VZReporting@doe.gov within ten days of the first transaction and every 90 days thereafter.

General Licence 54C: Items and Services for Coal or Minerals Operations

GL 54C, issued on 2 September 2026, replaces GL 54B in its entirety. It is the coal and minerals sector counterpart to GL 48C, authorising the provision from the United States or by a US person of goods, technology, software or services for the exploration, development, mining, extraction, processing, refining or production of coal or minerals, including gold, in Venezuela. As with GL 51D, Carbozulia is named alongside Minerven as part of the Government of Venezuela.

Authorised transactions include processing of payments, arranging shipping and logistics services including chartering vessels, obtaining marine insurance and P&I coverage, and arranging port and terminal services, together with maintenance of coal or minerals operations, including gold operations, and the refurbishment or repair of the relevant equipment.

Both the dispute resolution forum condition and the Foreign Government Deposit Funds condition apply.

GL 54C does not authorise non-commercially reasonable payment terms, debt swaps, gold payments or Venezuelan digital currencies; transactions involving persons located in or organised under the laws of Russia, Iran, North Korea, Cuba or China, or entities owned or controlled by or in a joint venture with such persons; the unblocking of blocked property; transactions involving a blocked vessel; or the formation of new joint ventures or other entities in Venezuela to explore, develop, mine, extract, process, refine or produce coal or minerals, including gold.

Reporting is to Sanctions_inbox@state.gov and ofac_intake@doi.gov within ten days of the first transaction and every 90 days thereafter.

General Licence 61A: Telecommunications

GL 61A, issued on 27 August 2026, replaces GL 61 (21 August 2026) in its entirety. It authorises the provision from the United States or by a US person of goods, technology, software or services for the installation, maintenance, refurbishment, repair, upgrade, operation or support of telecommunications in Venezuela, including transactions involving the Comisión Nacional de Telecomunicaciones ("CONATEL") and the Compañía Anónima Nacional Teléfonos de Venezuela ("CANTV").

Telecommunications is defined broadly, covering data, telephone, internet connectivity, radio, television, news wire feeds and similar services, regardless of the medium of transmission, including transmission by satellite or through submarine cables.

Of particular relevance to Members, authorised transactions expressly include arranging shipping, air freight, logistics, warehousing, insurance and delivery services, and the laying, maintenance, repair, refurbishment, upgrade, security, operation or support of submarine cables and other telecommunications infrastructure. Members operating cable-laying, cable repair or offshore support tonnage should note that this activity now falls within a general licence.

GL 61A carries the dispute resolution forum condition but, like GL 47B, no Foreign Government Deposit Funds payment condition.

GL 61A does not authorise non-commercially reasonable payment terms, debt swaps, gold payments or Venezuelan digital currencies; transactions involving persons located in or organised under the laws of Russia, Iran, North Korea, Cuba or China, or entities owned or controlled by or in a joint venture with such persons; the unblocking of blocked property; transactions involving a blocked vessel; or the formation of new joint ventures or other entities in Venezuela to develop or invest in the telecommunications sector.

Reporting is to Sanctions_inbox@state.gov only, within ten days of the first transaction and every 90 days thereafter.

The licence carries an express reminder that it does not relieve any person of the requirements of other federal agencies, including the Federal Communications Commission, the Committee for the Assessment of Foreign Participation in the US Telecommunications Services Sector, and the Department of Commerce's Bureau of Industry and Security.

Country restrictions: a comparison

The country-related carve-outs are not uniform, and the differences are easy to miss. The table below summarises the position under each of the eight principal licences:

A further drafting difference is worth noting: most of the licences exclude persons "located in or organised under the laws of" the listed countries, whereas GL 50C refers only to persons "located in" them. Members should not assume the formulations are interchangeable.

General Licence 30B: Port and Airport Operations – Update on INEA

Background

Members will recall our Notice to Members No. 19 2020/2021 which addressed the designation by OFAC of Venezuela's Maritime Authority, the Instituto Nacional de los Espacios Acuaticos ("INEA"), under Executive Order 13850 for operating in the oil sector of Venezuela and providing assistance to PdVSA. That circular explained the confusion the designation created for shipowners calling at Venezuelan ports for trades unrelated to oil, and described the introduction of GL 30A (issued February 2021) which authorised transactions ordinarily incident to Venezuelan port operations, including dealings with INEA.

GL 30B Replaces GL 30A

On 10 February 2026, OFAC issued GL 30B, which replaces and supersedes GL 30A (dated 2 February 2021) in its entirety.

GL 30B continues the authorisation of transactions that are ordinarily incident and necessary to the operation or use of ports and airports in Venezuela – including dealings involving INEA or any entity in which INEA owns, directly or indirectly, a 50% or greater interest.

GL 30B was not amended on 27 August 2026 and remains in force in its 10 February 2026 form. It is the licence on which port calls continue to rest.

What is New in GL 30B?

OFAC FAQ 1236 confirms the key change from GL 30A: GL 30B removes the prohibition on transactions or activities related to the exportation or re-exportation of diluents to Venezuela. That prohibition is no longer relevant given that GL 47B separately authorises such transactions.

GL 30B expressly authorises:

• Payment of port fees and customs duties in connection with Venezuelan port and airport operations;
• Transactions involving INEA and its majority-owned subsidiaries; and
• Port and airport transactions in support of activities authorised under the other Venezuela general licences.

Interaction with the Amended Licences

The general licences issued on 27 August 2026 continue to rely on GL 30B for port and airport access rather than authorising it themselves. Note 2 to paragraph (a) of GL 48C, Note 2 to paragraph (a) of GL 54C and Note 3 to paragraph (a) of GL 61A each direct the reader to GL 30B for the authorisation covering transactions ordinarily incident and necessary to the operation or use of ports and airports in Venezuela.      

Port dues, customs duties and INEA-related fees therefore continue to be authorised for voyages connected with activity under GL 46D, GL 47B, GL 48C, GL 49A, GL 50C, GL 51D, GL 52B, GL 54C and GL 61A.

It should be noted that GL 46D, 47B, 48C, 51D, 54C and 61A separately authorise the arranging of port and terminal services, including with port authorities or terminal operators that form part of the Government of Venezuela, in connection with the activity each licence covers. GL 30B remains the broader and more general authorisation, and is the one to rely on for port calls that are not tied to a specific commodity licence.

What GL 30B Does NOT Authorise

GL 30B does not authorise:

• Transactions otherwise prohibited by the VSR;
• Transactions with any blocked person other than INEA (or entities in which INEA owns 50% or more); or
• Dealings with any Government of Venezuela person that is blocked solely pursuant to EO 13884, unless separately authorised.

Non-US Persons and INEA

As was previously confirmed in the context of GL 30A, OFAC has indicated that non-US persons do not engage in sanctionable conduct by engaging in conduct that would be authorised by a General Licence if engaged in by a US person. As a matter of policy, the authorisation in GL 30B therefore applies by analogy to non-US persons.

Venezuela-related OFAC FAQs

OFAC maintains a growing body of Venezuela-related FAQs on its topic page. Following the action of 27 August 2026 the series runs to FAQ 1268. The FAQs of most immediate relevance to the current licences are:

• FAQ 1226 – meaning of "Venezuelan-origin oil"
• FAQ 1227 – scope of authorised activities
• FAQ 1229 – meaning of "established US entity"
• FAQ 1230 – provision of services by non-US persons
• FAQ 1232 – "commercially reasonable terms"
• FAQ 1233 – amended 27 August 2026: the dispute resolution requirement does not apply to indirect parties, including providers of shipping and insurance services
• FAQ 1235 – downstream trading once the blocked entity's interest is extinguished
• FAQ 1244 – amended 27 August 2026: OFAC's approach to specific licence applications to perform contingent contracts
• FAQ 1247 – amended 2 September 2026: sanctions risk for non-US persons engaging in transactions authorised by GL 46D, GL 51D and GL 52B
• FAQ 1267 – new: no choice of law provision is required
• FAQ 1268 – new: the dispute resolution forum requirement and its limits

FAQ 1260, which addressed the former US governing law requirement, was archived on 27 August 2026 and should no longer be relied upon.

Guidance for Members

Members considering engagement in Venezuelan trade should note the following:

Tanker owners and operators

• Shipowners chartering vessels to established US entities for the carriage of Venezuelan-origin oil are not required to be established US entities themselves. Non-US shipowners may provide transportation services ordinarily incident and necessary to a GL 46D transaction.
• Contracts between shipowners and the established US entity do not need to provide for dispute resolution in the United States, the United Kingdom, France or Singapore. That condition applies only to contracts directly with Venezuelan state counterparties, as amended FAQ 1233 confirms.
• Charterparties and contracts of carriage may be governed by English law or any other law the parties select. The removal of the choice of law condition on 27 August 2026 also means that contracts between an established US entity and PdVSA are no longer confined to US governing law, although the forum requirement continues to apply to them.
• Voyages involving blocked vessels remain prohibited regardless of the licence applicable to the cargo.
• INEA-related port dues and fees continue to be authorised under GL 30B, including for voyages connected with activity under GL 46D, GL 47B, GL 48C,  GL 49A, GL 50C, GL 51D, GL 52B, GL 54C and GL 61A. Banking delays remain a practical risk; consult your bank in advance.

Non-tank owners and operators:

Bulk and general cargo operators lifting Venezuelan-origin fertilizer or fertilizer precursor cargoes should check the cargo against the Annex to GL 46D, and should note that the petrochemical products authorisation covers importation into the United States only.

• Operators carrying Venezuelan-origin coal, minerals or gold should note the 30-day reporting cycle under GL 51D and the supply chain due diligence documentation that reports must contain. Coal was brought within this licence on 2 September 2026, and the reporting obligation is more onerous than that applying to oil cargoes.
• Cable-laying, cable repair and offshore support operators should note that GL 61A expressly authorises submarine cable work, subject to the FCC, Team Telecom and BIS requirements referred to in the licence.

Due diligence

Members must continue to conduct enhanced due diligence before engaging in any Venezuelan trade. In particular, Members should verify:

• That the party dealing directly with PdVSA, Minerven or the Government of Venezuela qualifies as an "established US entity" where the licence requires it;
• That the vessel involved is not on the OFAC SDN List as a blocked vessel;
• That no party in the transaction chain is located in or organised under the laws of Russia, Iran, North Korea or Cuba; and
• That the position on Chinese-connected parties has been checked against the specific licence relied upon.

Financial institutions may rely on customer confirmations of GL compliance, but Members should be prepared to demonstrate compliance with applicable licence conditions.

Members should identify, in each fixture, which general licence is being relied upon, and should check that the version cited is current. The licence numbering has changed repeatedly during 2026.

Conclusion

The general licences issued since January 2026 represent a significant and continuing shift in US policy toward Venezuela, selectively opening the oil, petrochemical, electricity, coal, minerals and telecommunications sectors to US and allied participation while maintaining the underlying sanctions framework and excluding Russian, Iranian, North Korean, Cuban and, in most respects, Chinese involvement.

The amendments of 27 August 2026 are directed at contractual mechanics rather than commercial scope. By removing the US choice of law requirement while retaining a four-jurisdiction dispute resolution requirement, OFAC has made it materially easier for non-US parties to contract with Venezuelan state counterparties on familiar terms, including under English law with London arbitration.

The situation continues to evolve rapidly, and OFAC has amended this family of licences repeatedly during 2026, most recently on 2 September. We will continue to monitor developments and will issue further Notices to Members as the position develops.

Important note

The information provided by the Club and in particular through its website is not and is not intended to be exhaustive. Every effort is made to ensure the accuracy of the information provided. However this cannot be guaranteed given that sanctions measures are subject to alteration by Governmental organisations at short notice. Further the information on this site is not, and should not be relied upon as, independent legal advice.

Members are strongly advised to undertake due diligence before fixing any business to or from a sanctioned country in order to ensure that neither the prospective cargo nor the parties to the planned venture are sanctioned. The Club is willing to assist Members where possible but they may nevertheless wish to take independent legal advice.