Venezuela General License 20B - Authorizing Official Activities of Certain International Organizations Involving the Government of Venezuela

Date issued: Jan. 21 2020

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TURBOFAC Commentary (958 words)


*Note common to certain GLs: This is one of 12 GLs that pre-dated the blocking of the Government of Venezuela, pursuant to EO 13884, and was amended to account for the blocking. Except as discussed below, the substance of what the GL authorizes remains unchanged as a result of EO 13884. OFAC did not amend any FAQ dealing primarily with this FAQ as a result of the blocking of the GOV.

1) By its terms, the GL is not limited to activities in which a U.S. person is a party to an underlying transaction. This means that U.S. persons may engage in ancillary transactions that would be subject to the otherwise-applicable prohibitions, even if such activities pertain to a transaction involving no U.S. person. This is not uncommon, but this GL is notable insofar...