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Case No. VENEZUELA-2017-346975-1
[***]
Arnold & Porter Kaye Scholer LLP
601 Massachusetts Avenue, NW
Washington, DC 20001
Dear Mr. [***]:
This letter responds to your request dated August 17, 2017, as supplemented on August 24, 2017, November 1, 2017, and September 4, 2018 (the “Application”) to the Office of Foreign Assets Control (OFAC), seeking confirmation that your firm, Arnold & Porter Kaye Scholer LLP (the “Firm”) may render and be paid for certain legal services to the Government of Venezuela (“GOV”) without a specific license, either because the services are being rendered to the GOV and not to a designated person or the services fall within the scope of the legal services and payments general licenses set forth in sections 591.506 and 591.507 of the Venezuela Sanctions Regulations, 31 C.F.R. part 591 (VSR), or in the alternative, to...
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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...