OFAC - Venezuela General License 6A - Authorizing Certain Activities Necessary to the Wind Down of Operations or Existing Contracts with Globovision Tele C.A. or Globovision Tele CA, Corp.

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.

TURBOFAC Commentary (868 words)

Notes:

*This is one of a handful of GLs that were active as of the date of the blocking of the Government of Venezuela that were not amended to account for that fact. Evidently, OFAC does not consider Globovision to meet the broad definition of "Government of Venezuela." Otherwise, OFAC would have either amended or revoked this in August, 2019.

1) See FAQ 648, addressing the scope of "maintenance" within the meaning of the original version of this GL. On Jan. 7, 2020, the GL was converted from a "maintenance" general license to a simple "wind down" general license with a two-week validity period.

2) Note the irregular structure as compared to other "maintenance" and/or "wind down" GLs (e.g. Ukraine GL 13). OFAC appears to specify that payments made in accordance with the...

Welcome!

Welcome!

Venezuela General License 6A (Expired) - Authorizing Certain Activities Necessary to the Wind Down of Operations or Existing Contracts with Globovision Tele C.A. or Globovision Tele CA, Corp.

TURBOFAC Commentary (868 words)