OFAC FAQ (Current) # 653 - Executive Order 13850 "Blocking Property of Additional Persons Contributing to the Situation in Venezuela"

Date issued: Jan. 31 2019

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TURBOFAC Commentary (1106 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.

First note that, unlike substantively related FAQ 524, this FAQ is issued in connection with EO 13850, a standard blocking executive order.

In FAQ 524, OFAC stated, in a roundabout way, that engaging in derivatives transactions, including credit default swaps, related to a reference bond subject to the prohibitions of EO 13808 is prohibited unless generally licensed. That FAQ did not necessarily say anything about the relationship between derivatives and standard blocking language, however, since...