OFAC Executive Order 13857 - Taking Additional Steps to Address the National Emergency with Respect to Venezuela (January 25, 2019)

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 (348 words)

Notes:

1) amends definitions of "Government of Venezuela" (GOV) in all previously issued Venezuela-related EOs, to include "and any person who has acted or purported to act directly or indirectly for or on behalf of, any of the foregoing, including as a member of the Maduro regime." The amended definition is the same one used in EO 13884, blocking the GOV.

The apparent purpose of this change is to maintain sanctions on persons and entities connected with the Maduro regime at the time the EO was issued, even though the U.S. government no longer recognizes those entities as being connected with what the U.S. considers to be the legitimate government of Venezuela. That notwithstanding, the addition of "purported to act" to the definition of Government of Venezuela may complicate diligence efforts with respect to those EOs restricting...

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Executive Order 13857 - Taking Additional Steps to Address the National Emergency with Respect to Venezuela (January 25, 2019)

TURBOFAC Commentary (348 words)