Venezuela Earthquake Relief License: Which Payments Bypass the FGDF?

Venezuela Earthquake Relief License: Which Payments Bypass the FGDF?

OFAC's October 16 amendment opens a narrow payment route for relief, while preserving the deposit rules on transactions outside that route. The payment test in Venezuela's earthquake-relief license turns on the transaction's purpose, not simply the identity of the recipient. Under General License 60A , funds can be processed or transferred on behalf of third-country persons to or from Venezuela in support of authorized earthquake relief. OFAC's FAQ 1263 says taxes, tolls and fees to the Government of Venezuela connected with that relief need not go into the Foreign Government Deposit Funds Account (FGDF). A payment outside G…