OFAC FAQ (Current) # 1248 - Venezuela Sanctions

Date issued: Apr. 14 2026

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TURBOFAC Commentary (200 words)

Notes:

1) All of the following GLs have a reporting requirement that applies on its face to “any person” that is engaged in certain specified activities pursuant to the GLs. Venezuela GL 46, Venezuela GL 47, Venezuela GL 48, Venezuela GL 50, Venezuela GL 51, Venezuela GL 52 and Venezuela GL 54. Some (e.g. GL 50) are so broad as to cover “[a]ny person that engages in transactions pursuant to this general license”. OFAC evidently did not appreciate that “any person” (on its face) could cover “any” of a dozen persons engaging in the same transaction pursuant to a given GL, and this FAQ seeks to remedy the undesirable result of requiring many persons to file the same or similar reports in connection with the same transaction. In doing so, OFAC sets out a “parties engaged...