OFAC FAQ (Current) # 652 - Executive Order 13850 "Blocking Property of Additional Persons Contributing to the Situation in Venezuela"

Date issued: Jan. 31 2019

Last substantive commentary amendment:
May. 08 2023

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TURBOFAC Commentary (636 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) This FAQ is ostensibly about Venezuela, but with obvious cross-programmatic application for all programs operating within the rubric of standard blocking language.

OFAC impliedly makes two statements about the scope of the term "interest," as it relates to "property" in which a blocked person has an "interest."

First, a blocked person has an "interest" in any debt, equity, or other holdings issued or owned by that person, even if such debt is held by a third-party fund.

Second, just because a blocked person's blocked debt is part of a fund, it does not render the entire fund "property" in which...