Venezuela General License 57 - Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals (April 14, 2026)

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TURBOFAC Commentary (539 words)

Notes:

1) This broadly transactions ordinarily incident and necessary the provision of (very broadly defined) “financial services” involving several banks blocked pursuant to EO 13850 and 13884, as well “[a]ny individual whose property and interests in property are blocked solely pursuant to Executive Order (E.O.) 13884 because that individual meets the definition of “Government of Venezuela,” as defined in E.O. 13884, including current employees of the “Government of Venezuela,” excluding any individual identified on the” List.

2) With respect to the “any individual” authorization, this should be read in light of GL Venezuela GL 34, which covers “Former employees and contractors of the Government of Venezuela” and “Current employees and contractors of the Government of Venezuela who provide health or education services in Venezuela, including at hospitals, schools, and universities”. Between the two GLs, all individual contractors and employees are covered, as are former contractors and employees. But what about current “contractors” that do not “provide health or education services in Venezuela”? Given the secondary sanctions safe harbor at FAQ # 1247 it would seem unlikely that OFAC considers all non-U.S. person entities operating consistent with the FAQ to be fully blocked persons due to their status as “contractors” (otherwise what good does the safe harbor do?)

3) The GL covers the provision of “financial services to, from, or for the benefit of the” otherwise blocked persons. “Financial services” is very broadly defined, but note that there a transaction is prohibited for reasons other than involvement of one of the blocked persons identified in the GL, some other form of authorization is required for the transaction. For example, a transaction involving payment to PdVSA requires authorization other that GL 57. This GL does, however, appear to authorize transactions where an underlying transaction is otherwise not prohibited (e.g. employment of a Venezuelan remote worker) and the only blocked person involvement is that of a bank listed in this GL. “Wire transfers” is listed as a covered “financial service,” and the GL would allow “wire transfers” to or from one of the listed banks. Transactions ordinarily incident to the wire transfers are authorized, but a hypothetical transaction involving the purchase of goods from PdVSA involving one of these banks does not qualify because, in that case, it is the wire transfer that is ordinarily incident to the purchase of the goods from PdVSA, not the other way around.

4) What exactly is OFAC trying to accomplish through paragraph (b)? Is the entire set of transactions authorized not already implicitly authorized under the standard “ordinarily incident” provision in the VSR (591.404)? It is possible that, absent paragraph (b), the GL could be read as excluding (say) transactions with GoV banking regulators necessary for the establishment of financial service relationship with the listed banks.

5) The definition of “financial services” includes “loans,” meaning that U.S. person can provide “loans” to the listed banks, and the GL licenses against the entirety of the VSR. Does this mean that U.S. person investors can provide “loans” to the Central Bank of Venezuela (i.e. the Central Bank of Venezuela issues “new debt”?) OFAC may not have intended this GL to serve that function, but the four corners of the GL appear to accommodate that result.

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Venezuela General License 57 - Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals (April 14, 2026)

TURBOFAC Commentary (539 words)