Venezuela General License 39B - Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19)

Date issued: Jun. 14 2023

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TURBOFAC Commentary (1442 words)


* GL amended on 6-10-22 and 6-14-23 to extend the expiration date.

1) Background -Notes Common to the Three “COVID GLs” Issued 6-17-2021

On 6-17-2021, OFAC issued Added Venezuela GL 39, Syria GL 21 and Iran GL N. All three GLs (collectively “the COVID GLs”) are designed to address the same problem—i.e. OFAC-administered sanctions’ prevention of certain COVID-related trade—but the GLs are scoped differently in light of the nature of the three sanctions regimes to which they pertain.

2) Interpretive Issues Common to the Three COVID GLs

Interpretive issues connected to the GLs can be divided between those that are common to all three GLs, and those that are unique to each individual GL. OFAC’s FAQs issued concurrent with the issuance of the GLs,...