Case No. VENEZUELA-2017-346975-1

Date issued: Jan. 03 2019

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (530 words)

Notes:

1) This guidance letter was issued at a time when the VSR (and Venezuela-related sanctions program in general) included EO 13808 (GoV-related new debt prohibitions with a 30-day debt tenor), EO 13692 (used to designated certain GoV officials) and EO 13850 (blocking certain persons), but not EO 13884 (blocking the entirety of the GoV). At the time of the application, EO 13850 had not been issued, but it was issued prior to the date of the OFAC letter. The law firm Applicant reports having provided legal services to the GoV, more specifically Banco de Desarrollo Economico y Social de Venezuela (BANDES), at a time when the provision of those services was not prohibited due to the blocking prohibition of EO 13884 or any other EO (BANDES was designated pursuant to EO 13850 after the letter was sent). Invoices for...