Venezuela General License 23 - Third-country Diplomatic and Consular Funds Transfers Authorized

Date issued: Aug. 05 2019

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TURBOFAC Commentary (525 words)

Notes:

1) Provision type common to all programs involving blocked governments, though with significant variations across programs. Compare 560.541 (ITSR), 542.517 (SySR), 510.515 (CACR) and 510.515 (NKSR).

2) One notable difference of this GL as compared to its analogues is use of the construction "involving the Government of Venezuela" in "involving the Government of Venezuela that are necessary for the operating expenses or other official business of third-country diplomatic or consular missions in Venezuela." Evidently, the reason for "involving the Government of Venezuela" is that, without the involvement of the GOV, the funds transfer would be outside the scope of the applicable prohibitions altogether (here, the blocking of the GOV). In full embargo programs, a funds transfer to a third country mission in a sanctioned destination is an export of services to that destination, whether or...