Case No. VENEZUELA-EO13850-2021-373786-1

Date issued: Feb. 04 2022

Last substantive commentary amendment:
May. 01 2023

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TURBOFAC Commentary (971 words)

Consolidated Comment on Case No. VENEZUELA-EO13850-2021-373786-1 and LICENSE No. VENEZUELA-EO13850-2021-373786-1

1) BACKGROUND

Case No. VENEZUELA-EO13850-2021-373786-1 and LICENSE No. VENEZUELA-EO13850-2021-373786-1 pertain to real property in Florida that was blocked due to indirect ownership by an SDN. As described in Case No. VENEZUELA-EO13850-2021-373786-1, the condo association filed a foreclosure complaint against the company that owned the real property in Florida state court, and the Florida state court granted the motion for default judgment, which led to the foreclosure sale of the property to the applicant. All of this happened without OFAC having issued a license (and presumably without OFAC even being aware of the events).

2) "NULL AND VOID" JUDGMENTS; A RARE "RETROACTIVE LICENSE"

In theory the underlying judgment that led to the foreclosure sale was "null and void". See 591.202 of the VSR:

"(a) Any...