OFAC FAQ (Current) # 1259 - Venezuela Sanctions

Date issued: Jun. 10 2026

TURBOFAC Commentary (256 words)

Notes:

1) FAQ clarifies that Venezuela GL 30B covers the receipt of “ground services in-country” from GoV entities in the context of “private and commercial flights”. The GL also helpfully interprets the term “ordinarily incident and necessary” in the context of “ordinarily incident and necessary to the operation or use of airports in Venezuela” to specify that this includes “the provision of baggage and ground handling services; safety and security services; airport operational services; air navigation and overflight services; fuel and into-plane services; and the payment of aeronautical, customs, immigration, and other government-imposed fees and taxes.”

2) Notably, OFAC specifies that “[a]dditionally, U.S. sanctions programs issued pursuant to the International Emergency Economic Powers Act (IEEPA), including the Venezuela Sanctions Regulations, do not generally prohibit transactions ordinarily incident to travel to or from any country.” This confirms that the travel exemption applies to the VSR generally, notwithstanding that the VSR has no explicit travel exemption provision. Refer generally to General Note on the Applicability of IEEPA/TWEA Exemptions in EOs and Sanctions Regulations not Specifically Mentioning Them. It is notable that the exemption portion of the FAQ is phrased in a way that may suggest that some of what which is authorized by the GLs may be exempt in any event. Most of the transactions described are likely not exempt (refer to Notable Examples Illustrating the Scope of the Travel Exemption), but some, in particular “payment of…immigration…fees and taxes,” clearly are, at least in the context of payments associated with individuals’ travel.