Venezuela General License 33 - Authorizing Overflight Payments, Emergency Landings, and Air Ambulance Services

Date issued: Aug. 05 2019

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (705 words)

Notes:

1) Compare SySR and CACR analogues (542.518 and 515.548). A version of this GL appears in all embargo programs, but with varying scopes.

2) The existence of this GL suggests that OFAC does not consider overflights of U.S.-related aircraft to be "ordinarily incident" to travel, and therefore exempt from regulation. If overflights themselves were exempt, payments for overflights would also be exempt. See Civil Enforcement Information - Spirit Airlines, Inc (2008) for overflight-related enforcement action. The same is true of air ambulance services. What the GL does not clarify, however, is whether overflights of a sanctioned destination are necessarily within the scope of OFAC's jurisdiction to begin with, presuming that no "services" are received in connection with the overflight.
...