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OFAC updates Venezuela General License 31, and issues an updated FAQ

This is an exception – this is not a limited time General License being renewed for another time period. Two important changes – first, the GL now authorizes transactions with a broader class of persons (it used to be just people appointed by Guaido):

(b) Except as provided in paragraph (c) of this general license, U.S. persons are authorized to engage in all transactions and activities involving any person appointed by Guaidó, the IV National Assembly, or its Delegated Commission to the board of directors (including any ad hoc board of directors) or appointed as an executive officer of a Government of Venezuela entity (including entities owned or controlled, directly or indirectly, by the Government of Venezuela) prohibited by E.O. 13850 of November 1, 2018, as amended by E.O. 13857 of January 25, 2019, and incorporated into the VSR.
And in the list of “this isn’t authorized”, the National Assembly was added:
(1) Any transaction or activity involving the Venezuelan National Constituent Assembly convened by Nicolas Maduro or the illegitimate National Assembly scheduled to be seated on January 5, 2021, including their respective members and staff; or
And Frequently Asked Question (FAQ) 679 was updated to incorporate the changes:

679. Executive Order 13884 of August 5, 2019, “Blocking Property of the Government of Venezuela,” blocks all property and interests in property of the Government of Venezuela. What does this mean for the Government of the Interim President of Venezuela?

Answer

The United States stands with the Venezuelan people and current Interim President of Venezuela Juan Gerardo Guaidó Marquez (“Guaidó”) in opposition to the illegitimate Maduro regime.  On January 4, 2021, OFAC issued General License 31A authorizing transactions and activities involving the current Interim President of Venezuela, the IV Venezuela National Assembly seated on January 5, 2016 (“IV National Assembly”), and its Delegated Commission, including respective members and staff, that are otherwise prohibited by E.O. 13884.  The authorization also covers transactions and activities prohibited by E.O. 13850, as amended, with respect to certain persons appointed by Guaidó, the IV National Assembly, and its Delegated Commission.

In addition, General License 31A authorizes transactions and activities involving any official, designee, or representative appointed or designated by Guaidó to act on behalf of the Government of Venezuela, including the Special Attorney General, and any staff of the foregoing individuals; any ambassador or other representative to the United States or to a third country appointed by Guaidó, and any staff of such ambassador or representative; any representative to an international organization appointed by Guaidó, and any staff of such representative; any person appointed by Guaidó to the board of directors (including any ad hoc board of directors) or appointed as an executive officer of a Government of Venezuela entity (including entities owned or controlled, directly or indirectly, by the Government of Venezuela); and any other person that is appointed or designated by any of the foregoing persons to act on behalf of the Government of Venezuela.

General License 31A replaced and superseded General License 31, dated August 5, 2019.
 

Links:

OFAC Notice

General License 31A

FAQ 679

Categories: Frequently Asked Questions (FAQ) Guidance Licenses OFAC Updates Venezuela sanctions

eric9to5

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