OFAC FAQ (Current) # 516 - Venezuela Sanctions - Executive Order 13808 of August 24, 2017

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (175 words)

Notes:

1) Read in conjunction with FAQ # 395, the leading FAQ on new debt prohibitions and letters of credit. This FAQ. like that one, clarifies what is meant by "debt of" an entity subject to new debt prohibitions. The prohibitions only apply when the sanctions target is the person to whom credit is extended in some fashion.

2) Note: this FAQ and comments thereto were posted/written prior to the blocking of the Government of Venezuela pursuant to 13884. Neither the FAQ nor the comment have been updated in light of that development.

3) Compare FAQ 515 and Section 1(b) of the EO. For a U.S. person to deal with the Government of Venezuela as it acts as underwriter in connection with debt issued by a non-sanctioned issuer would not be prohibited. On its face, however, Section 1(b) of the EO would prevent the purchase from the Government of Venezuela of that same debt.

* See generally General Note on the Prohibitions on Dealings in “New Debt” of Certain Sanctions Targets (System Ed. Note)

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OFAC FAQ (Current) # 516 - Venezuela Sanctions - Executive Order 13808 of August 24, 2017

TURBOFAC Commentary (175 words)