El "overcompliance" discrecional no debe constituirse en medida que atente contra los derechos civiles, económicos ni humanos de los ciudadanos ni están por encima de los principios jurídicos fundamentales de un sistema democrático.
On August 5. 2019, U.S. Executive Order 13884 barred all U.S. persons from doing business with the government of Venezuela. As a result, many firms have decided to halt interactions with Venezuelan nationals, regardless of their links to the admnistration of Nicolás Maduro.
In one recent example, on October 7 Adobe Inc. announced it was deactivating all accounts in Venezuela. In its announcement, it explained that the August 5 executive order barred almost all transactions between U.S. companies and businesses in Venezuela. Adobe is just one example of several companies that have decided to curtail or eliminate any business with Venezuelans.
We request that the U.S. Treasury Department issue a General License exempting providers of software services from the restrictions embodied in U.S. Executive Orders as regards the provision of services to Venezuelan individuals and firms. Treasury must also issue clear guidance through its Frequently Asked Questions site clarifying that U.S. businesses will not be penalized for doing business with Venezuelan citizens or firms.