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OFFICE OF FOREIGN ASSETS CONTROL
Venezuela Sanctions Regulations
31 C.F.R. Part 591
GENERAL LICENSE NO. 30A
Authorizing Certain Transactions Necessary to Port and Airport Operations
(a) Except as provided in paragraph (c) of this general license, all transactions and activities involving the Government of Venezuela prohibited by Executive Order (E.O.) 13884 of August 5, 2019, as incorporated into the Venezuela Sanctions Regulations, 31 C.F.R. part 591 (the VSR), that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela are authorized.
(b) Except as provided in paragraph (c) of this general license, all transactions and activities prohibited by E.O. 13850 of November 1, 2018, as amended by E.O. 13857 of January 25, 2019, and incorporated into the VSR, involving the Instituto Nacional de los Espacios Acuaticos (INEA), or...
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1) This GL is unique to the EO 13884. Evidently, U.S. persons are involved with the actual operation of certain Venezuelan ports and airports. To that end, this GL permits the activity to continue.
Less clear, and potentially more consequential, is the scope of the term "ordinarily incident to...use of ports and airports."
Venezuela General License 24 (Certain Transactions Involving the Government of Venezuela Related to Telecommunications and Mail Authorized) already allows all transactions of common carriers moving packages in and out of Venezuela, and this presumably includes dealings connected to ports and airports in connection with activities as common carriers.
Arguably, most "use" of ports that not connected to the movement of cargo would be covered by the travel exemption.
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