On 6 August 2019, after US Government promulgated new sanctions on Venezuela, the OFAC published a General License which expressly permit payments to the Venezuelan Government for filing, prosecution and maintenance of patent, trademark, copyright or other forms of intellectual property protection in Venezuela, including opposition and infringement proceedings.
Caracas, Venezuela, August 8, 2019 – General License 27 published by the OFAC (Office of Foreign Assets Control) on August 6, permit payments to the Venezuelan Government for filing, prosecution and maintenance of patent, trademark, copyright or other forms of intellectual property protection in Venezuela, including opposition and infringement proceedings.
New sanctions of US Government (Executive Order Blocking Property of the Government of Venezuela; EO 13884) prohibit US individuals or companies from engaging in transactions with the Government of Venezuela, by broadening the definition of Government of Venezuela to include not only the state and named officials but now, also, all property and property interests of the Government of Venezuela (Section 6(d), e.g., political subdivisions, agencies, entities and persons controlled directly or indirectly by the government).
In case of intellectual property matters in Venezuela, the Office of Foreign Assets Control (OFAC) published on August 6, 2013, 13 new general licenses that excused US persons from the terms of the Executive Order. In particular, General License 27 authorize transactions in connection with the protection of intellectual property rights in the US or Venezuela. Expressly permitted are the filing, prosecution and maintenance of any patent, trademark, copyright, or other form of intellectual property protection in Venezuela, as well as the filing and prosecution of opposition or infringement proceedings with respect to an IP right, or the entry of a defense in such proceedings.
General License 27 authorizes US persons to pay fees to the Government of Venezuela, and to pay reasonable and customary fees and charges to attorneys and representatives within the US or Venezuela in connection with intellectual property transactions. (https://www.treasury.gov/resource-center/sanctions/Programs/Documents/venezuela_gl27.pdf)