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OFAC designated the China National Electronic Import-Export Company ("CEIEC") to the Specially Designated Nationals and Blocked Persons List ("SDN List") for the company's role in undermining Venezuelan democracy.
In General License No. 38 ("GL 38"), OFAC authorized the wind down of transactions involving CEIEC through January 14, 2021, which otherwise would be prohibited by Executive Order 13692 ("Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela"). OFAC specified that the General License does not authorize (i) any debit to a CEIEC account on a U.S. financial institution's books or (ii) any transactions otherwise prohibited by the Venezuela Sanctions Regulations.
In a related FAQ, OFAC explained that all wind-down activities must be completed (not initiated) prior to the January 14 expiration of GL 38, and that new business with CEIEC will not be considered wind-down activity.
In addition to covering wind-down activities of U.S. persons, GL 38 authorizes non-U.S. persons to wind down their dealings with CEIEC without exposure to secondary sanctions under Executive Order 13692.
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