OFAC FAQ (Current) # 1247 - Venezuela Sanctions

Date issued: Mar. 31 2026

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TURBOFAC Commentary (569 words)

Notes:

1) OFAC’s guidance at FAQ # 7 states that “non-U.S. persons do not generally risk being sanctioned for engaging in or facilitating transactions for which a U.S. person would not require a specific license.” Meanwhile, Venezuela GLs Venezuela General License 46B, Venezuela General License 51 and Venezuela General License 52 each apply to transactions “by an established U.S. entity” (defined to mean “any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.” Given that actually being an “established U.S. entity” within the meaning of the GL is effectively a condition for use of the GL, there appears to be no mechanism for applying the secondary sanctions related safe harbor at FAQ # 7 to transactions of non-U.S. persons that are...