In general, the parties engaged in the primary authorized activity are responsible for complying with the applicable reporting requirements in these Venezuela-related GLs. Parties that are only indirectly involved or providing services ancillary to the primary authorized activity are not required… Read more
Yes. Venezuela-related General License (GL) 30B authorizes U.S. persons to engage in all transactions involving the Government of Venezuela (GOV), including its agencies and instrumentalities like the Instituto Nacional de Aeronáutica Civil (INAC) and Instituto Nacional de los Espacios Aquaticos (… Read more
While E.O. 13884 blocks all property and interests in property of the Government of Venezuela that come into the possession or control of U.S. persons or U.S. jurisdiction, the Venezuelan people are not subject to comprehensive U.S. sanctions. Sanctions do not preclude U.S. persons from exporting… Read more
No. GL 60 authorizes all transactions related to earthquake relief efforts in Venezuela under the Venezuela Sanctions Regulations, which includes payment of taxes, tolls, and fees to the Government of Venezuela connected with such relief efforts. Payments related to earthquake relief that are… Read more
To obtain payment account information for payments to the Foreign Government Deposit Funds deposit account established consistent with Executive Order (E.O.) 14373 , "Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People," and referenced in certain Venezuela General… Read more
The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity… Read more
GL 61 authorizes transactions ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the installation, maintenance, refurbishment, repair, upgrade, operation, or support of telecommunications in Venezuela,… Read more
Specific license applications to perform any contingent contracts executed pursuant to GL 49 will be assessed on a case-by-case basis consistent with U.S. foreign policy and national security priorities. Recent Venezuela-related general licenses issued by OFAC have included various limitations in… Read more
No. The dispute resolution requirement in certain Venezuela General Licenses (GL), (e.g., 46D , 47B , 48B , 50C , 51C , 52B , 54B , and 61A ) only requires that contracts governing transactions with the Government of Venezuela (GOV) or certain other blocked persons (e.g., Petróleos de Venezuela, S.… Read more
Yes. Certain Venezuela general licenses (GLs), including 46D , 47B , 48B , 50C , 51C , 52B , 54B , and 61A , require that any contract for authorized transactions with the Government of Venezuela or certain other blocked persons (e.g., Petróleos de Venezuela, S.A. in GL 52B or CVG Compañía General… Read more