OFAC FAQ (Current) # 649 - Executive Order of January 25, 2019 “Taking Additional Steps to Address the National Emergency with Respect to Venezuela”

Date issued: Jan. 28 2019

TURBOFAC Commentary (196 words)

Notes:

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) See comments to each of the individual EOs that this EO amends for comments on the significance of the change of the scope of the definition of "Government of Venezuela."

2) The apparent purpose of this change is to maintain sanctions on persons and entities connected with the Maduro regime at the time the EO was issued, even though the U.S. government no longer recognizes those entities as being connected with what the U.S. considers to be the legitimate government of Venezuela. For further detail on the scope of the term "Government of Venezuela" that is common to all Venezuela-related EOs, see General Note on the Scope of Executive Order 13884 (Blocking the Government of Venezuela) (System Ed. Note).

3) See FAQ 513 and comments thereto. In spite of the change, the definition of "Government of Venezuela" still does not necessarily reach all entities owned 50% but not otherwise controlled by the Government (e.g. certain joint ventures).