On September 9, 2019, the Office of Foreign Assets Control of the US Department of the Treasury issued General License 34, which authorizes transactions and activities otherwise prohibited by Executive Order 13884, provided that the current or former employees of the Government of Venezuela who have an interest in the subject property are US citizens, US permanent resident aliens, non-diplomat persons in the US on an immigrant or non-immigrant visa, or former employees and contractors of the government of Venezuela.
The general license resolves an extremely broad application of the Executive Order, which adopted an unprecedented definition of “Government” of Venezuela that included a blocking of all former and current employees and those who had acted on behalf of any Government of Venezuela entity.