OFFICE OF FOREIGN ASSETS CONTROL
Venezuela Sanctions Regulations
31 CFR part 591
GENERAL LICENSE NO. 57
Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals
(a) Except as provided in paragraph (c) of this general license, all transactions prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (VSR), that are ordinarily incident and necessary to the provision, exportation, or reexportation, directly or indirectly, of financial services to, from, or for the benefit of the following persons are authorized:
(1) Banco Central de Venezuela;
(2) Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela);
(3) Banco Digital de los Trabajadores Banco Universal C.A.;
(4) Banco del Tesoro, C.A. Banco Universal (Banco del Tesoro);
(5) Any entity in which one or more of the above persons...
1) This GL 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” SDN 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”....