LICENSE No. VENEZUELA-EO13850-2019-359374-1

Date issued: Feb. 26 2019

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TURBOFAC Commentary (432 words)

Notes:

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...