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Case No. VENEZUELA-2018-351167-1
Jorge Chaban
Proambiente, SA LLC
1390 Brickel Avenue, Suite 200
Miami, FL 33131
Dear Mr. Chaban:
This letter responds to your request dated February 16, 2018 and supplemental information received on June 19, 2018, to the Office of Foreign Assets Control (OFAC) (the “Application”) on behalf of Proambiente, SA LLC, requesting authorization to collect and receive payments for invoices issued to Petroleos de Venezuela, S.A. (PdVSA) pursuant to contracts pre-dating August 25, 2017, for oil services provided to PdVSA.
As you know, on August 24, 2017, the President issued Executive Order 13808 “Imposing Additional Sanctions with Respect to the Situation in Venezuela” (“E.O. 13808”), which prohibits, among other things, all transactions related to, provision of financing for, and other dealings by a U.S. person or within the United States in new debt...
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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...