Venezuela General License 34A​ - Authorizing Transactions Involving Certain Government of Venezuela Persons

Date issued: Nov. 05 2019

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TURBOFAC Commentary (1440 words)

Notes:

1) This GL was issued on 9 Sept. 2019--around five weeks after the initial blocking of the entire Government of Venezuela (GOV) and issuance of GLs authorizing many transactions involving the GOV--evidently to mitigate the effects of the unusual breadth of the definition of "Government of Venezuela" that appears in EO 13884.

Government of Venezuela is defined in EO 13884 as including:

"the state and Government of Venezuela, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A. (PdVSA), any person owned or controlled, directly or indirectly, by the foregoing, and any person who has acted or purported to act directly or indirectly for or on behalf of, any of the foregoing, including as a member of the Maduro regime." (emphasis added)...