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

Date issued: Aug. 05 2019

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TURBOFAC Commentary (686 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.
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