General Note on the Venezuela Sanctions Regulations, the Blocking of the Government of Venezuela and other Venezuela-related EOs (System Ed. Note)

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TURBOFAC Commentary (1558 words)

General Note on the Venezuela Sanctions Regulations, the Blocking of the Government of Venezuela and other Venezuela-related EOs (System Ed. Note)

1) BACKGROUND

The Venezuela sanctions architecture is extremely complex, and highly irregular in comparison to other sanctions programs. As of 8/2019, OFAC has issued six separate EOs containing prohibitions related to Venezuela, and one EO amending the definition of Government of Venezuela ("GOV") as it appears in the five prohibition-containing EOs issued prior. The Venezuela-related EOs are as follows:

Executive Order 13692 - Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela (March 8, 2015 - Appendix A to Part 591—Executive Order 13692)
Executive Order 13808 - Imposing Additional Sanctions with Respect to the Situation in Venezuela (August 24, 2017)
Executive Order 13827 - Taking Additional Steps to Deal with the Situation...