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OFFICE OF FOREIGN ASSETS CONTROL
Executive Order 13884 of August 5, 2019
Blocking Property of the Government of Venezuela
GENERAL LICENSE NO. 35
Authorizing Certain Administrative Transactions with the Government of Venezuela
(a) Except as provided in paragraph (b) of this general license, U.S. persons are authorized to pay taxes, fees, and import duties to, and purchase or receive permits, licenses, registrations, certifications, and public utility services from, the Government of Venezuela, to the extent such transactions and activities are prohibited by Executive Order (E.O.) 13884, where such transactions are necessary and ordinarily incident to such persons' day-to-day operations.
(b) This general license does not authorize any transaction or dealing otherwise prohibited by E.O. 13884, or E.O. 13850 of November 1, 2018, E.O. 13835 of May 21, 2018, E.O. 13827 of March 19,...
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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...