Case No. VENEZUELA-2018-354698-1

Date issued: Aug. 25 2018

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TURBOFAC Commentary (306 words)

Notes:

1) The request for interpretive guidance to which this letter response was made after the issuance of EO 13835, but prior to the issuance of the first iteration of Venezuela General License 5, which authorized "all transactions related to, the provision of financing for, and other dealings in the Petroleos de Venezuela SA 2020 8.5 Percent Bond that would be prohibited by Subsection 1(a)(iii) of Executive Order 13835 of May 21, 2018," where Subsection 1(a)(iii) prohibits "the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela of any equity interest in any entity in which the Government of Venezuela has a 50 percent or greater ownership interest..." After the issuance of the guidance letter, OFAC began issuing versions of Venezuela GL 5 that only applied after a specified date in the...