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OFFICE OF FOREIGN ASSETS CONTROL
Venezuela Sanctions Regulations
31 CFR part 591
GENERAL LICENSE NO. 59
Authorizing the Supply of Certain Items and Services Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A. (Conviasa)
(a) Except as provided in paragraph (c) of this general license, all transactions prohibited by Executive Order (E.O.) 13884 involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A. (Conviasa), or any entity in which Conviasa owns, directly or indirectly, a 50 percent or greater interest (collectively, “Conviasa Entities”), or any aircraft in which Conviasa or a Conviasa Entity has an interest, and that are ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the maintenance, repair, upgrade, refurbishment, improvement, safety, or airworthiness of such aircraft,...
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1) Read in conjunction with Venezuela General License 45B (transactions related to repatriation flights involving Conviasa).
2) Unusual entity-specific GL authorizes all transactions “ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the maintenance, repair, upgrade, refurbishment, improvement, safety, or airworthiness of” aircraft in which Conviasa has an “interest”. Between provision of “goods, technology, software, or services,” this appears to amount to essentially all conceivable transactions related to “the maintenance, repair, upgrade, refurbishment, improvement, safety, or airworthiness of” covered aircraft, where OFAC specifies that transactions covered by that language “include processing of payments, arranging shipping, logistics, customs clearance, and delivery services; the sale, supply, installation, inspection, testing, maintenance, repair, replacement, refurbishment, upgrade, or improvement of aircraft parts, components, equipment, software, and technology;...