OFAC Issues General Licenses Authorizing Certain Transactions With Venezuela, Revokes Turkey Licenses

The Treasury’s Office of Foreign Assets Control amended and issued Venezuela-related general licenses and revoked two Turkey general licenses, according to a Nov. 5 notice. OFAC also published new and amended frequently asked questions to explain the Venezuela-related licenses.

OFAC amended General License 34A to authorize certain transactions with current employees or contractors of the Venezuelan government who “provide health or education services” within the country, including at hospitals, schools and universities, according to a FAQ. The license replaces General License 34.

The newly issued license, General License 35, authorizes certain “administrative actions,” OFAC said, including payments related to taxes, fees, import duties, permits, licenses, registrations, certifications and public utility services from Venezuela’s government. The license allows those transactions only if they are “necessary and ordinarily incident to such persons' day-to-day operations,” the license said.

U.S. people or companies who use General License 35 must file a report with OFAC and the Department of State with the names and addresses of any entities sending the payment and any Venezuelan entities receiving the payment, the amount of money paid, the “type and scope of activities conducted” and the payment dates. The license specifies that U.S. financial institutions are not required to submit the reports on behalf of customers or third parties. The license also includes dates by which the reports must be submitted and provides methods to submit the reports.

In a FAQ, OFAC said users “should remain cautious … to ensure all criteria for use of the general license are met” and referenced the Nicolas Maduro regime’s “long history of corruption.” OFAC said “U.S. persons who rely on the authorization in General License 35 to exercise appropriate due diligence to ensure compliance with the terms of the authorization.” The agency said it is “prepared to revoke this authorization.”

OFAC also revoked General License 2, which authorized certain transactions with Turkey’s government agencies that were “necessary to the wind down of operations.” The license was set to expire Nov. 13. The agency also revoked General License 3, which authorized certain transactions for “official business” by the United Nations with Turkey. The licenses, originally issued Oct. 14, were the result of the short-lived sanctions imposed on Turkey by the Trump administration in October for Turkey’s military operations in Syria. Trump lifted the sanctions about one week after imposing them (see 1910230030).