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1263. Does General License (GL) 60 require that payments to the Government of Venezuela be made into the Foreign Government Deposit Funds Account (FGDF)?
No. GL 60 authorizes all transactions related to earthquake relief efforts in Venezuela under the Venezuela Sanctions Regulations, which includes payment of taxes, tolls, and fees to the Government of Venezuela connected with such relief efforts. Payments related to earthquake relief that are authorized by GL 60 do not need to be paid into the FGDF.
However, the requirements under other Venezuela-related GLs, such as GLs 46C, 48B, 49A, 50B, 51B, 52A, and 54A, remain in place. Payments for activities outside of the scope of GL 60 but authorized under other Venezuela-related GLs that contain the FGDF payment requirement must continue to be paid into the FGDF and may not be recharacterized as earthquake relief or otherwise modified for the purpose of...
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1) FAQ clarifies what is clear from the face of Venezuela GL 60, i.e. that "Payments related to earthquake relief that are authorized by GL 60 do not need to be paid into the FGDF". The apparent purpose of the FAQ is to put the regulated public on notice that " Payments for activities outside of the scope of GL 60 but authorized under other Venezuela-related GLs that contain the FGDF payment requirement must continue to be paid into the FGDF and may not be recharacterized as earthquake relief or otherwise modified for the purpose of avoiding payment into the FGDF."