October 18, 2023 Venezuela Looseleaf Introduction and FAQ - # 1 (Updated on April 17, 2024, previous versions included)

Date issued: Apr. 17 2024

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TURBOFAC Commentary (320 words)

Note:

1) The initial version of this preface and FAQ does not provide interpretive guidance concerning the scope of any of the authorities cited. Refer to comments to Venezuela General License 3, Venezuela General License 9, Venezuela General License 43 and Venezuela General License 44 for further comments.

2) The version revised on 2-2-24 formalizes OFAC's intent to not renew Venezuela General License 44 “absent progress between Maduro and his representatives and the opposition Unitary Platform”. See Venezuela GL 43A in re: Minerven.

3) The version revised on 4-17-24 provides guidance concerning the scope and operation of the Venezuela General License 44A wind-down license. OFAC notes that “[e]ntering into new business, including new investment, that was previously authorized under GL 44 will not be considered wind-down activity,” which is generally consistent with OFAC’s...