Frequently Asked Questions

721 … Yes, a person subject to U.S. jurisdiction engaging in authorized travel-related transactions may travel to Cuba from a third country or to a third country from Cuba. Persons subject to U.S. jurisdiction traveling to and from Cuba via a third country may only do so if their travel-related… Read more

505 … No. The designation of an official of the Government of Venezuela does not mean that the government itself is also blocked. The prohibitions apply to transactions or dealings only with the individuals and entities whose property and interests in property are blocked. However, U.S. persons… Read more

507 … Yes, but prohibitions on dealing in new debt vary based on whether the entity involved is a PdVSA entity or another part of the Government of Venezuela. Subsection 1 (a)(i) of E.O. 13808 prohibits engaging in transactions related to, providing financing for, or otherwise dealing in debt if (1… Read more

508 … No. E.O. 13808 , as amended by E.O. 13857 , does not authorize the blocking of property. E.O. 13808, however, should be read in conjunction with other Venezuela-related authorities, such as the E.O. 13884 , which blocks the Government of Venezuela, and E.O. 13850, as amended, under which… Read more

509 … General License 1, which expired on September 25, 2017, provided a wind-down period with respect to contracts and other agreements that were in effect prior to August 25, 2017. That general license provided 30 days in which to conduct all transactions and activities otherwise prohibited by… Read more

510 … OFAC has issued four general licenses related to E.O.13808 . General License 1, which expired on September 25, 2017, applied to contracts and other agreements that were in effect prior to August 25, 2017. It provided 30 days in which to conduct all transactions and activities otherwise… Read more

527 … For purposes of Subsection 1(a)(iv) of E.O. 13808 , “profit” is net income after taxes. For a business, this is generally total sales minus total costs and expenses. For example, transactions involving the Government of Venezuela, including PDVSA, related to payments for goods and services,… Read more

547 … U.S. persons are generally prohibited from engaging in transactions or dealings with persons named on OFAC’s SDN List, including dealing with an SDN in the context of efforts to restructure Venezuelan and Petroleos de Venezuela, S.A. (PdVSA) debt.  Provided there is no SDN involvement,… Read more

548 … Yes. For purposes of E.O. 13808 , the prohibition in Subsection 1(a)(i) would apply to PdVSA and extend to all PdVSA subsidiaries, unless authorized by OFAC. Note that General License 2 authorizes certain activities involving specified PdVSA subsidiaries. … Subsection 1(a)(i) of E.O. 13808… Read more

511 … The term debt includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper. The term equity includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership. The… Read more