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If this is your first time here, take a look at our FAQ page and get a sense of our unique scope of coverage by perusing the Research System interface.
Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.
Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).
Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category).
Please contact [email protected] or [email protected] with any questions on search results and efficiency.
Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.
Date issued: Feb. 10 2026
*This is one of several Venezuelan energy sector-related GLs issued since the U.S. military operation resulting in the capture of Nicolás Maduro. See Venezuela General License 46A, Venezuela General License 47, Venezuela General License 48, Venezuela General License 49 and Venezuela General License 50.
1) Compare Venezuela General License 46 (oil trading) and Venezuela General License 47 (diluents). This GL authorizes “provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, or production of oil or gas in Venezuela,” subject to make of the same conditions and under a similar structure as the other two GLs. The interpretive note to paragraph (a), which serves as an implicit interpretation of the term “ordinarily incident and necessary to” in the context of the transactions authorized, helpfully confirms that this includes “transactions for the maintenance of oil or gas operations in Venezuela, including the refurbishment or repair of items used for oil or gas exploration, development, or production activities”.
2) A significant difference between this GL and the other two is that the “[a]ny transaction involving a person” carveout includes China.
3) Query: with respect to the reference to Venezuela GL 30B, when would reliance on that GL be needed for a transaction not otherwise authorized as ordinarily incident to a transaction covered in paragraph (a)?
4) See FAQ # 1237, concerning the scope of " local taxes, permits, or fees."