Venezuela General License 32 - Authorizing Certain Transactions Related to Personal Maintenance of Individuals who are U.S. Persons Residing in Venezuela

Date issued: Aug. 05 2019

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TURBOFAC Commentary (595 words)

Notes:

1) Refer to the Research System for a multitude of interpretive guidance letters pertaining to the ITSR that could shine some light on how OFAC would be likely to interpret certain language concerning individuals living in a different country, in particular what is ordinarily incident and necessary to personal maintenance within a different country.

2) The ITSR version of this GL (560.552) pertains to U.S. citizens residing in Iran, while the Syrian and Venezuelan versions pertain to (the broader) "U.S. persons" residing in those countries. However, it is not clear what OFAC considers to constitute “residency” for these purposes. It may or may not be the “ordinarily resident” test used in other contexts.

Can a U.S. person that is in but is...