OFAC FAQ (Current) # 650 - Executive Order 13850 "Blocking Property of Additional Persons Contributing to the Situation in Venezuela"

Date issued: Feb. 11 2019

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TURBOFAC Commentary (339 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) FAQ amended on 11 Feb, 2019 to account for the amendment to GL 9, expanding the scope of the GL from "debt" to "debt" and "equity," as well as the amendment to GL 3, adding to that GL a provision requiring transfers of covered instruments to be to non-U.S. persons.

2) OFAC offers a "safe harbor" for financial institutions or registered broker-dealers processing transactions in securities that may be subject to prohibitions. The structure of the safe harbor is awkward as it blends the language of the one afforded to intermediary financial institutions (expectation of diligence with respect to...