Last Thursday, April 16, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued guidance for the provision of humanitarian and trade assistance to combat COVID-19, regarding individuals, governments or entities facing difficulties with sanctions.
The purpose of the informative guide is to summarize and highlight those cases in which, exceptionally, states such asIran, North Korea, Syria, Cuba, Venezuela, among others, are exempt and authorized for trade and humanitarian assistance with natural or legal persons of U.S. origin.
In the specific case of VenezuelaIt should be recalled that on August 05, 2019, the Department of the Treasury, through Executive Order 13,884 sanctioned the Venezuelan government, which has generated a siege on its economy.
The document published by the Department of the Treasury details those activitiesThe company has dedicated a section in which it refers to frequently asked questions, as well as general licenses, to transactions or operations that are permitted by the United States.
With respect to frequently asked questions, the Treasury Department clarifies that persons wishing to have relations or transactions with the people of Venezuela may carry out such transactions as long as they are not related to sanctioned persons or entities, or are subject to prohibition. For its part, the guide reiterates that humanitarian assistance activities, as well as the supply of items such as food, clothing and medicines with the Government of Venezuela, are not prohibited.
General licenses for humanitarian assistance.
General licenses were developed under OFAC's Venezuela program which describe the activities that will not be considered subject to sanctions, among which the guide highlights the following:
- General License 4Cwhich authorizes transactions for the export or re-export of agricultural products, medicines, medical devices, as well as their spare parts or components. Including test kits, respiratory devices, personal protective equipment and drugs used for the prevention, diagnosis, treatment and recovery of COVID-19.
- General License 16CIn addition, all transactions and activities to process personal remittances are authorized through financial institutions, which include Banco de Venezuela, Banco Bicentenario del Pueblo, Banco de la Clase Obrera, Banco de la Mujer y Comunas, Banco del Tesoro, C.A., and Banco Central de Venezuela.
- General License 20BThis law authorizes transactions subject to U.S. jurisdiction, international organizations such as the United Nations, its programs, funds, and related agencies and organizations, as well as the International Committee of the Red Cross, among others, to carry out transactions through the Central Bank of Venezuela and persons of the Venezuelan Government.
- General License 26authorizes the provision and receipt of unscheduled medical emergencies related to the Government of Venezuela.
- General License 29The Company authorizes non-governmental organizations to carry out transactions related to the Venezuelan Government dedicated to humanitarian, construction and education projects for the benefit of Venezuelans and the environment.
- General License 30 authorizes activities related to the Venezuelan Government, which must necessarily make use of ports and airports in Venezuela.
- General License 33, authorizing, among other activities, operations or transactions involving the Government of Venezuela necessary to provide air ambulance and related medical services, including medical transportation from Venezuela, for persons in Venezuela.
At the time of publication of this note, the National Executive confirmed having received humanitarian aid from the International Red Cross..