Venezuela General License 30A - Authorizing Certain Transactions Necessary to Port and Airport Operations

Date issued: Feb. 02 2021

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TURBOFAC Commentary (807 words)

Notes:

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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