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LICENSE No. VENEZUELA-EO13850-2019-359374-1
VENEZUELA SANCTIONS REGULATIONS
LICENSE
Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, Pub. L. 113-278, Executive Orders 13692, 13808, 13827, 13835, 13850, and 13857, and 31 C.F.R. Parts 501 and 591.
To: Citgo Petroleum Corporation
c/o Willkie Farr & Gallagher LLP 1875 K Street, NW
Washington, DC 20006
Attn: Michael Gottlieb
1. Based upon the request dated February 20, 2019, and information otherwise available to the Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and instructions issued under one or more of the authorities cited above.
3....
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1) At the time this license (p.5 of .PDF) was issued, Citgo Petroleum Corporation was a U.S. person that was blocked pursuant to EO 13850 for being owned by PDVSA S.A. (Venezuela), an SDN. Because Citgo Petroleum Corporation was a U.S. person and blocked pursuant to the 50% rule, the entity needed a license from OFAC to engage in virtually any activity that would constitute a “dealing in property in which Citgo has an interest." Here, a license was issued for the “activities ordinarily incident and necessary to winding down its insurance contracts with PDV Insurance Company, Ltd.”
Refer to the comments at LICENSE No. VENEZUELA-EO13850-2019-359381-1, LICENSE No. VENEZUELA-EO13850-2019-359381-2, discussing other licenses related to dealings between CITGO and PDV Holding Insurance Company. Notwithstanding the expiry and non-renewal of this license, CITGO was still authorized to...