new U.S. Sanctions at The Government Of Venezuela #Our_WebsiteJanuary 14, 2020
President Trump signed a new Executive Order on August 5, 2019, Executive Order 13884 (“EO 13884”), which blocks (i.e., freezes) all property of the Venezuelan government and its political subdivisions, agencies, and instrumentalities, including the Central Bank of Venezuela and Petroleos de Venezuela (“PdVSA”).
Rather, EO 13844 is focused on the Government of Venezuela, blocking all of the government’s property in the United States and prohibiting all U.S. persons from transactions, direct or indirect, with the Government of Venezuela, unless authorized by a general or specific license.
EO 13844 is significant for all U.S. persons with business dealings in Venezuela, even those that principally involve non-government actors, because many dealings in Venezuela require interaction with government authorities at various levels.
Right now there is no indication that the U.S. government will designate specific Government of Venezuela entities on the Specially Designated Nationals and Blocked Persons List (“SDN List”), which is the case with certain other sanctions programs covering foreign governments, such as Iran.
Like most sanctions-related Executive Orders, EO 13884 authorizes U.S. authorities to designate any person (including non-U.S. persons) determined (i) to have “materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of” any person designated on the SDN List whose property and interests in property are blocked pursuant to the Order, or (ii) to be “owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order.” This provision allows for “collateral” designation of non-U.S. persons that otherwise do not come directly under the scope of the sanctions prohibitions.
General License 22 : Authorizes U.S. persons to provide goods or services to Venezuela’s mission to the United Nations, including payment for goods and services.
General License 28 : Provides authority, until 12:01 a.m.
persons are generally prohibited from engaging in transactions with the Government of Venezuela” or with entities owned 50 percent or more, directly or indirectly, by the Government of Venezuela.
While EO 13884 does not prohibit U.S. persons from engaging in transactions involving Venezuela per se, U.S. persons must ensure that their activities in Venezuela do not involve any blocked persons and are not otherwise prohibited by preexisting sanctions (unless authorized by general or specific license).
OFAC specifically states that it “expects financial institutions to conduct due diligence on their own direct customers (including, for example, their ownership structure) to confirm that those customers are not persons whose property and interests in property are blocked.” In instances where the financial institution is merely an intermediary but fails to block a transaction involving a target of U.S. sanctions, “OFAC will consider the totality of the circumstances surrounding the bank’s processing of the transaction to determine what, if any, regulatory response is appropriate.” FAQ No.
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