On 5 August 2019 the Trump Administration issued an executive order imposing additional sanctions on the Government of Venezuela that specifically allows “transactions related to provision of articles such as food, clothing and medicine intended to be used to relive human suffering.” The next day the Department of Treasury issued a guidance document that explains specific authorizations for transactions relating to humanitarian assistance, medical services, remittances and nongovernmental organizations’ transactions with the government of Venezuela. The guidance includes authorization for financial institutions to conduct transactions in support of these permissible activities.
The new executive order, titled, “Blocking Property of the Government Venezuela” freezes assets subject to U.S. jurisdiction, prohibits transactions with it (unless covered by humanitarian and other authorizations in the guidance) and imposes travel restrictions. It allows the Treasury Department, in consultation with the Secretary of State, to add persons who provide the Venezuelan government with direct or indirect support to the sanctions list (Specially Designated Nationals).
The guidance document includes description of three General Licenses issued by the Office of Foreign Assets Control (OFAC) in the Department of the Treasury in conjunction with the new executive order. They are as follows:
- General License No. 26, which authorizes emergency and certain other medical services.
- General License No. 29, which authorizes certain transactions involving the government of Venezuela in support of certain nongovernmental organizations’ activities. This General License specifically mentions “processing and transfers of funds” from the Venezuelan government.
- General License 4C, which authorizes certain new debt transactions and other transactions involving certain blocked persons related to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates.