519. How can I help the Venezuelan people while making sure to abide by the U.S. sanctions?
While E.O. of August 5, 2019 blocks all property and interests in property of the Government of Venezuela that come into the possession or control of U.S. persons or U.S. jurisdiction, the Venezuelan people are not subject to comprehensive U.S. sanctions. Sanctions do not preclude U.S. persons from exporting or reexporting items to Venezuela provided that the transactions do not involve sanctioned individuals or entities or certain prohibited activities. Those involved in exports or reexports to Venezuela, including exports or reexports related to activity authorized by OFAC, should also consult the Department of Commerce’s Bureau of Industry and Security to ensure eligibility of exportation or reexportation under its authorities. Likewise, the E.O. of August 5, 2019 does not prohibit transactions involving the Government of Venezuela that relate to the provision of articles such as food, clothing, and medicine intended to be used to relieve human suffering. OFAC has also issued General License 4C to authorize further transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to Venezuela, or to persons in third countries purchasing specifically for resale to Venezuela. See General License 4C for details and relevant definitions.
In addition, OFAC maintains several complementary general licenses designed to support assistance to the Venezuelan people. General License 16B authorizes transactions and activities ordinarily incident and necessary to processing noncommercial, personal remittances involving certain financial institutions. General License 20A authorizes official activities of certain international organizations to engage in transactions with the Government of Venezuela. General License 24 authorizes transactions involving the Government of Venezuela incident to the receipt and transmission of telecommunications, as well as transactions of common carriers involving the Government of Venezuela incident to the receipt or transmission of mail and packages between the United States and Venezuela. General License 25 authorizes the exportation or reexportation, directly or indirectly, from the United States or by U.S. persons, wherever located, to or involving the Government of Venezuela of services, software, hardware, and technology incident to the exchange of communications over the Internet. General License 26 authorizes the provision and receipt of nonscheduled emergency medical services, and the provision of other medical services involving the Government of Venezuela. General License 29 authorizes nongovernmental organizations to engage in activities with the Government of Venezuela in support of humanitarian projects, democracy building, education, non-commercial development projects directly benefiting the Venezuelan people, and environmental protection in Venezuela.
In addition to these general licenses, OFAC can also issue specific licenses to authorize particular transactions that may otherwise be prohibited by the sanctions, as long as those transactions are in the foreign policy interests of the United States. For additional information, please see FAQ 665 and OFAC’s “Guidance Related to the Provision of Humanitarian Assistance and Support to the Venezuelan People.” [08-06-2019]
1) This FAQ was initially issued subsequent to the blocking of the Central bank of Venezuela, and was amended to account for the blocking of the entire Government of Venezuela. Refer generally to Guidance Related to the Provision of Humanitarian Assistance and Support to the Venezuelan People (comments thereto), the individual GLs mentioned in the FAQ, and comments to EO 13884. The FAQ does not provide interpretive guidance.