Sanctions-related Statute - Venezuela Defense of Human Rights and Civil Society Act of 2014 [Selected provisions]

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (279 words)

Notes:

1) For a discussion of the evidently limited-to-nonexistence practical impact of this statute, see General Note on the Venezuela Sanctions Regulations, the Blocking of the Government of Venezuela and other Venezuela-related EOs (System Ed. Note). In short, there are two Venezuela related EOs that cite this statute as authority, and therefore "implement" the statute to some degree, but OFAC does not appear to consider any Venezuelan to be designated "pursuant to" this statute. Part of the reason for this may be that the designation criteria in Sec. 5 of the statute are far narrower than those that appear in the EOs that partially implement the statute, especially 13580, providing for sectoral sanctions that are quite clearly not within the scope of this statute. Compare comments to Executive Order 13851 of November 27, 2018 - Blocking Property of Certain Persons Contributing to the Situation in Nicaragua. OFAC has designated persons pursuant to a Nicaragua-related statute that is broadly similar to this one, where there is an EO that covers substantially the same ground as the associated EO, but when it has done so, it is made explicit.

For practical purposes, the fact that designations are not made pursuant to this statute means that the import exception in the statute does not apply. See General Note on "Import Exceptions" in Certain Program-Specific Sanctions Statutes (System Ed. Note). The flipside of that, however, is that persons designated pursuant to EOs "implementing" this statute are presumably eligible for favorable licensing policy treatment under TSRA. See General Note on the Cross Programmatic Relevance of , as it relates to Agricultural Commodities, Medicine and Medical Devices (System Ed. Note).

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Venezuela Defense of Human Rights and Civil Society Act of 2014 [Selected provisions]

TURBOFAC Commentary (279 words)