Case No. VENEZUELA-2018-353444-1

Date issued: Nov. 25 2019

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TURBOFAC Commentary (342 words)

Notes:

1) This is one of several guidance letters addressing the Venezuela-related EO 13808 new debt prohibition in the context of collection of payments from PdVSA and/or entities owned by PdVSA. Here, OFAC recounts that the applicant seeks authorization to “engage in the collection and receipt of the overdue payments…that may be charged in connection with [***] commercial invoices issued between [***] by [Applicant] to several companies majority-owned by Petroleos de Venezuela, S.A.” OFAC states that “these invoices were issued pursuant to the terms and conditions set forth in [***] contracts between [Applicant] and PDVSA Companies…” OFAC’s conclusion is “it appears that the outstanding invoices are for goods or services purchased under purchase orders or contracts that were entered into prior to August 25, 2017. Provided that the terms of those purchase orders or contracts have not been modified on or after...