513. Do the prohibitions imposed pursuant to E.O. 13808 and subsequent Venezuela-related E.O.s also extend to entities owned 50 percent or more by the Government of Venezuela?

In general, yes. These prohibitions apply to transactions related to the Government of Venezuela, which is defined in E.O. 13808 to include all entities owned or controlled by the Government of Venezuela. This would normally include entities owned 50 percent or more by the Government of Venezuela because in most instances such entities would be considered controlled by the Government of Venezuela. Also included are any entities that are less than 50% owned, but otherwise controlled, by the Government of Venezuela. Note, however, that General License 2 authorizes all transactions otherwise prohibited by Subsections 1(a)(i), (a)(ii), and (b) of E.O. 13808 provided that the only Government of Venezuela entities involved in the transactions are CITGO Holding, Inc. or its subsidiaries. General License 3 also authorizes all transactions related to, provision of financing for, and other dealings in bonds issued prior to August 25, 2017, by U.S. person entities owned or controlled, directly or indirectly, by the Government of Venezuela.