OFAC FAQ (Current) # 1233 - Venezuela Sanctions

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (167 words)

Notes:

[8-27-26 update – FAQ amended to address all GLs with a dispute resolution requirement, rather than 46 only]

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

2) This FAQ interprets the term “such transactions with the Government of Venezuela, PdVSA, or PdVSA Entities” as it appears in paragraph (a) of GL 46. OFAC’s guidance makes clear that “transactions with” does not mean “transactions involving”. Instead, it applies only when the actual “contract” at issue is “with” GoV entities (i.e. they are a party to the contract). Query how this works in the context of a situation where a U.S. entity purchases product from a non-U.S. entity, who in turn has purchased it from PdVSA. Does the U.S. entity’s ability to transaction depend on whether the underlying...

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OFAC FAQ (Current) # 1233 - Venezuela Sanctions

TURBOFAC Commentary (167 words)