Venezuela General License 35​ - Authorizing Certain Administrative Transactions with the Government of Venezuela

Date issued: Nov. 05 2019

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TURBOFAC Commentary (468 words)

Notes:

1) Among sanctions programs involving blocked governments, Venezuela GL 35 is unique, and appears to represent a substantial softening of the effects of the blocking of the Government of Venezuela (GOV). The term "day-to-day operations" presents some difficult interpretive questions. FAQ # 803 says "we encourage U.S. persons who rely on the authorization in General License 35 to exercise appropriate due diligence to ensure compliance with the terms of the authorization." Presumably, OFAC is thinking in particular about ensuring that no transactions involve persons blocked pursuant to Venezuela-related authorities other than EO 13884. See Russia-related General License 13, for similar GL (with not much in the way of associated guidance on the meaning of “day-to-day”, except for FAQ # 1118).

*General Note re: The Relationship Between Venezuela-related Loose-leaf...