OFAC FAQ (Current) # 1227 - Venezuela Sanctions

Date issued: Feb. 06 2026

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TURBOFAC Commentary (595 words)

Notes:

1) See comments to Venezuela GL 46 for consolidated comment on the GL.

2) This FAQ provides a helpful illustrative list, beyond that which is described in the interpretive note contained in the GL of activities that are “ordinarily incident and necessary to the lifting (which refers to the physical loading and removal of oil from a terminal, storage facility, or production site for delivery to a buyer), exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil”. Note that OFAC also defines the term “lifting” in this FAQ, which appears aimed at clarifying that the GL does not cover exploration and pre-lifting production activities.

3) While this at least partially an interpretation of the term “ordinarily incident and necessary” as it appears in the text of...