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.
1) This is an across-the-board, Venezuela-related "official business" general license. The fact that all five prohibition-containing Venezuela-related executive orders are listed in the heading illustrates how OFAC considers these EOs to function as separate mini-regimes.
2) In November, 2019, OFAC amended the VSR such that 591.201 prohibits all conduct prohibited by any Venezuela-related EO, rather than just the prohibitions of EO 13692. Concurrent with that broad amendment to the VSR, OFAC added 591.407 and transferred the substance of Venezuela General License 14 to 591.509 (Official business of the United States Government). 591.509 implements this GL into the VSR, with no difference in substantive scope across the GLs. After implementation into the VSR, the loose-leaf version was revoked.
3) While the scope of teh GL as implemented in 591.509 is no different than it was when it existed as Venezuela General License 14, note that, as of 9/2021, "Note 1 to § 591.509" is the only provision in the VSR or its related GLs that cross references the interpretive provision at 591.407. 591.407 provides as follows:
Notwithstanding the existence of any general license issued under this part, or issued under any Executive order issued pursuant to the national emergency declared in E.O. 13692, the entry into a settlement agreement or the enforcement of any lien, judgment, arbitral award, decree, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property blocked pursuant to §591.201, as referenced in §591.506(c), is prohibited unless authorized pursuant to a specific license issued by OFAC pursuant to this part.
4) For detailed commentary on the scope and operation of the “official business” exemptions and GLs, see General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof.
5) Query: is the issuance of a writ of attachment on debt or equity subject to non-blocking prohibition authorized as "official business" of the U.S. government? See Case No. VENEZUELA-EO13884-2023-1057131-1, License No. VENEZUELA-EO13884-2023-1057131-1, and comments thereto.