521. I want to provide long-term financing to the Government of Venezuela to help with the exportation or reexportation of agricultural commodities, medicine, medical devices, components, or replacement parts and components for medical devices to Venezuela. Is that allowed?
Yes. General License 4 authorizes all financing and other dealings in new debt related to the exportation or reexportation of agricultural commodities, medicine, medical devices, components, or replacement parts for medical devices, to Venezuela, or to persons in third countries purchasing specifically for resale to Venezuela, provided that the exportation or reexportation is licensed or otherwise authorized by the Department of Commerce. Note, however, that General License 4 does not otherwise authorize any transaction that is prohibited by E.O. 13808, E.O. 13692, or any part of 31 C.F.R. Chapter V. [08-25-2017]
Note: this FAQ and comments thereto were posted/written prior to the blocking of the Government of Venezuela pursuant to EO 13884. Neither the FAQ nor the comment have been updated in light of that development.
1) Query whether and to what extent OFAC must license, without regard to its particular policy prerogatives, exports of TSRA-covered goods even to Venezuelan SDNs that are not otherwise excluded from the scope of TSRA as result of designations pursuant to terror and/or narcotics-related authorities. Refer to General Note on the Cross Programmatic Relevance of TSRA, as it relates to Agricultural Commodities, Medicine and Medical Devices (System Ed. Note). Note however that while this GL covers products that are generally within the scope of TSRA, the issue of this GL is not in any way a reflection of OFAC's views as to what is required to authorize as a result of that statute.