Case No. VENEZUELA-2018-351921-1

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 (673 words)

Notes:

1) In Case No. VENEZUELA-EO13850-2018-358633-1, OFAC determines that the Venezuela “new debt” prohibition of 13808 does not apply to invoices “for goods or services purchased under a contract that was entered into prior to August 25, 2017” (i.e. the sanctions effective date). In that case, “the agreement [pursuant to which the debts arose] was signed in June 2017, which was then extended by agreement in May 2018.” OFAC determined that “it appears that the invoices are for goods or services purchased under a contract that was entered into prior to August 25, 2017. Provided that the terms of the invoices or the contract have not been modified on or after August 25, 2017, except as identified in the Application, the invoices would not constitute ‘new debt,’ and therefore no additional authorization is needed from OFAC…to be paid…” In

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Case No. VENEZUELA-2018-351921-1

TURBOFAC Commentary (673 words)