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Case No. VENEZUELA-EO13850-2018-358633-1
[ ]
Rothwell Energy Services, LLC
c/o [ ]
2001 K Street, NW
Washington, DC 20006
Dear Ms. Latour:
This letter responds to correspondence dated November 26, 2018, July 26, 2019, November 7, 2019, and April 12, 2021, submitted on behalf of Rothwell Energy Services, LLC (“Rothwell”) to the Office of Foreign Assets Control (OFAC) requesting an authorization to collect from CITGO Petroleum Corporation (CITGO) $1,252,691.33 for CITGO’s obligations to Rothwell for work completed prior to the termination of the Service Contract Agreement (the “Agreement”) between CITGO and Rothwell and $1,130,317.37 for CITGO’s reimbursement obligations to Rothwell after termination of the Agreement (collectively, the “Invoices”) (the “Application”) as well as subsequent correspondence submitted on behalf of Rothwell in March and April 2021 regarding the March 12, 2020 interpretive guidance letter OFAC issued...
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1) Read in conjunction with Case No. VENEZUELA-2018-358633-1, and the associated license at License No. VENEZUELA-EO13850-2018-358633-1.
In this cover letter, OFAC “updating the guidance issued to Rothwell on March 12, 2020,” without reversing its prior legal interpretation, in light of “ further review of the information provided by Rothwell”. Specifically, OFAC concludes that “it appears that certain Invoices may constitute ‘new debt’ issued after August 24, 2017 with a maturity of greater than 90 days of PdVSA and may pertain to goods or services provided to PdVSA…” Due to the fact that the contract may have “pertain[ed] to goods or services provided to PdVSA”, neither Venezuela GL 2 nor Venezuela GL 7 would apply at all, and the old debt vs. “new debt” distinction would, where “new debt” of PDVSA is...