OFAC FAQ (Current) # 1247 - Venezuela Sanctions

Date issued: Sep. 02 2026

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (593 words)

Notes:

[UPDATE - FAQ amended on 9-2-26 to account for reissuance of GLs 46D, 51D, and 52B to add "coal" to the authorization scope]

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...