OFAC FAQ (Current) # 680 - Executive Order of August 5, 2019, “Blocking Property of the Government of Venezuela” (PDF contans all versions)

Date issued: Jan. 09 2023

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TURBOFAC Commentary (481 words)

Notes:

1) This is a straightforward application of the 50% rule, which blocks by operation of law entities in which a blocked person (or government) owns, in the aggregate with other blocked persons, a 50% or greater interest. EO 13884 also blocks, by operation of law and without an affirmative determination by OFAC, a variety of other entities meeting the definition of Government of Venezuela (GOV), including entities controlled, but not owned, by the GOV. Note however that not all persons blocked as a result of the application of the 50% rule to the GOV are entities meeting the definition of "Government of Venezuela." Unlike other sanctions programs involving blocked governments (e.g. ITSR, SySR and NKSR),...