On September 9, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Venezuela-related general license (General License 34) to authorize transactions involving certain Government of Venezuela-related individuals that would otherwise be prohibited by Executive Order (“EO”) 13884.

EO 13884 blocks all property of the Government of Venezuela. The “Government of Venezuela” is defined broadly in EO 13884 to include any person who has acted or purported to act directly or indirectly for or on behalf of the Government of Venezuela. Our previous blog post on the issuance of EO 13884 is available here. A previous general license authorizing activities that were ordinarily incident and necessary to the wind-down of operations, contracts or other agreements with the Government of Venezuela in general expired on September 4, 2019.

General License 34 is much narrower in scope and only authorizes all transactions and activities involving certain individuals who (1) meet the definition of the “Government of Venezuela” (as defined in EO 13884), and (2) are (i) US citizens or permanent resident aliens of the United States, or (ii) in the United States and have a valid US immigrant or nonimmigrant visa (other than those who are part of Venezuela’s mission to the United Nations), or (iii) former employees and contractors of the Government of Venezuela.

General License 34 also authorizes all transactions necessary to unblock property or interests in property that were blocked pursuant to EO 13884, including the return or processing of funds, for the individuals described above. The unblocking of property by US persons as described above requires a report to be filed with OFAC by mail or via email within 10 business days from the date the property is unblocked.

OFAC also amended its Frequently Asked Question 680 regarding the ability of US persons to transact with the Government of Venezuela, to reference this new General License 34.


Maria helps clients keep up with trade regulations, sanctions matters and foreign investment requirements that apply to their their cross-border transactions and investments. Maria has experience advising on the international trade sanctions, export and import controls, and foreign investment reviews by the Committee on Foreign Investment in the United States.


Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.


Ms Stafford Powell advises on all aspects of outbound trade compliance, including compliance planning, risk assessments, licensing, regulatory interpretations, voluntary disclosures, enforcement actions, internal investigations and audits, mergers and acquisitions and other cross-border activities. She develops compliance training, codes of conduct, compliance procedures and policies. She has particular experience in the financial services, technology/IT services, travel/hospitality, telecommunications, and manufacturing sectors.