Case No. VENEZUELA-2018-351167-1

Date issued: Oct. 08 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 (306 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. Here, OFAC recounts that the applicant seeks authorization “to collect and receive payments for invoices issued to [PdVSA] pursuant to contracts pre-dating August 25, 2017, for oil services provided to PdVSA.” At the time the guidance letters was issued, PdVSA was blocked pursuant to EO 13884 and EO 13850. As it relates to the EO 13808 new debt prohibition, OFAC states that “it appears that the outstanding invoices are for goods and 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 August 25, 2017, the purchase orders or contracts and related...