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Case No. VENEZUELA-EO13850-2019-364861-1
Universal Weather and Aviation, Inc.
c/o Adam P. Schwartz
Carlton Fields
4221 W. Boy Scout Boulevard, Suite 1000
Tampa, FL 33607
Dear Mr. Schwartz:
This letter responds to your correspondence dated December 4, 2019 (the “Application”) on behalf of Universal Weather and Aviation, Inc. (“Universal”) to the Office of Foreign Assets Control (OFAC) requesting a specific license to pay invoices of Commerchamp, S.A., a subsidiary of Petroleos de Venezuela, S.A. (PdVSA) for services and transactions incident to providing and/or arranging fuel uplift services prior to January 28, 2019, for certain Universal clients who use Universal’s UVair Fueling Card Program.
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...
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1) Compare related LICENSE No. VENEZUELA-EO13850-2021-372516-1, and the related application, from which we understand that Universal Weather (i) sought to pay invoices of PdVSA-owned Commerchamp in its capacity as an intermediary, and (ii) sought to be paid by PdVSA (all out of blocked funds).
Universal Weather provided the following background:
Universal is a privately held company based in Houston, Texas that provides flight planning and trip support services to business aviation.
Until it sold the business in March 2020, Universal coordinated refueling services for customers traveling to various countries through its UVair Fuel Program.
In Venezuela, PdVSA provided the refueling services. PdVSA’s affiliate, Commerchamp, S.A., invoiced Universal for those services. Universal, in turn, invoiced its customers for payment of the fuel, and Universal paid Commerchamp, S.A.
While Universal has provided no further refueling in Venezuela since PdVSA was...