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854. What does General License 38 authorize?


On November 30, 2020, OFAC designated CEIEC pursuant to Executive Order (E.O.) 13692 for its role in undermining democracy in Venezuela.  Concurrent with this action, OFAC issued Venezuela General License (GL) 38 (“Authorizing the Wind Down of Transactions Involving CEIEC”).  GL 38 authorizes U.S. persons to engage in all transactions and activities prohibited by E.O. 13692 that are ordinarily incident and necessary to the wind down of transactions and activities involving CEIEC, or any entity in which CEIEC owns, directly or indirectly, a 50 percent or greater interest (collectively, Blocked CEIEC Entities), through 12:01 a.m. eastern standard time, January 14 , 2021.

After the expiration of this authorization, unless exempt or authorized by OFAC, U.S. persons will be prohibited from engaging in transactions with the Blocked CEIEC Entities, and must block property or interests in property of such entities that are in, or come within, the United States, or the possession or control of a U.S. person.

Non-U.S. persons may wind down transactions and activities with the Blocked CEIEC Entities without exposure to sanctions under E.O. 13692, provided that such wind-down activity is: (i) consistent with GL 38; and (ii) completed prior to 12:01 a.m. eastern standard time, January 14, 2021.  Entering into new business involving the Blocked CEIEC Entities will not be considered wind-down activity.  Non-U.S. persons unable to wind down activities with the Blocked CEIEC Entities before 12:01 a.m. eastern standard time, January 14, 2021, may seek guidance from OFAC.

Date Released
November 30, 2020