OFAC issued a general license and related FAQ (see here and here, respectively) to facilitate the "wind down" of transactions involving two entities and their respective vessels that are designated under EO 13850 ("Blocking Property of Additional Persons Contributing to the Situation in Venezuela").

OFAC sanctioned the two entities and their respective vessels on June 18, along with three individuals and six other foreign entities, for alleged activities to evade U.S. sanctions against Venezuela's oil sector. Under General License 37, OFAC authorized, until July 21, 2020, most transactions and activities ordinarily incident and necessary to the wind down of business involving the entities.

In FAQ 834, OFAC explained that, in addition to authorizing transactions by U.S. persons, the General License also permits non-U.S. persons to engage in covered wind-down activities without fear of exposure to secondary sanctions.

Originally published June 22, 2020.

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