General Note on the Scope of Executive Order 13884 (Blocking the Government of Venezuela) (System Ed. Note)

Last substantive commentary amendment:
Mar. 27 2023

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TURBOFAC Commentary (2913 words)

General Note on the Scope of Executive Order 13884 (Blocking the Government of Venezuela) (System Ed. Note)

1) RELATION TO THE REST OF THE VENEZUELA PROGRAM


Executive Order 13884 blocks the Government of Venezuela (GOV) pursuant to standard blocking language. See Notes Common to most "Prohibited transactions" and "Prohibited transactions involving blocked property" Provisions; an Introduction to the Basic Blocking Language (System Ed. Note).

The EO operates independent all other Venezuela EOs, all of which involve the GOV in one way or another. Up until November 2019, the EO had virtually no relationship to the Venezuela Sanctions Regulations (VSR), but in November 2019, 591.201 of the VSR was amended to prohibit all activities prohibited by EO 13884, meaning that the definitional, interpretive and other boilerplate provisions of the VSR apply to EO 13884. However, as...