Venezuela General License 25 - Exportation of Certain Services, Software, Hardware, and Technology Incident to the Exchange of Communications over the Internet Authorized

Date issued: Aug. 05 2019

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TURBOFAC Commentary (1512 words)

Notes:

[4-10-22 update. Compare Russia-related General License 25, another particularly broad version of the internet services-related GL].

1) This is an internet-related GL bearing some resemblance to 560.540 (ITSR), 542.511 (SySR) and Ukraine General License Number 9. There are, however, major differences that make the GL unique. Most notably, the three internet services GLs referred to above are for "internet services" only. This GL says that it covers "hardware and technology" as well. Further, the GL is not limited to free services, and there is no limitation pertaining to blocked governments (indeed the entire GL applies only to a blocked government). Finally, the GL authorizes "services, software, hardware, and technology incident to the exchange of communications over the Internet," as opposed to the "personal communications"-related items authorized by 560.540 (ITSR), 542.511 (SySR)...