OFAC FAQ (Current) # 1232 - Venezuela Sanctions

Date issued: Feb. 06 2026

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TURBOFAC Commentary (142 words)

Notes:

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

2) To the extent that the “commercially reasonable terms” portion of the interpretive note to paragraph (a) of GL 46 serves as an explicit statement of what is always required of “ordinarily incident” transactions, this statement has cross-programmatic relevance. Notably, OFAC evidently does not consider the inherent market distortions that arise from the “military-involved” nature of the Venezuelan oil export context as a whole to render the terms on which such oil is sold “commercially unreasonable”. Instead of indicating that terms must reflect those of an undistorted market, the “commercially reasonable terms” condition appears aimed primarily at precluding circumvention of sanctions by, for example, making or receiving payments in kind that benefit PdVSA beyond what could be justified by the value of...