Case No. VENEZUELA-EO13850-2022-954785-1 (Final, Application Included)

Date issued: Nov. 09 2023

Last substantive commentary amendment:
Feb. 21 2024

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TURBOFAC Commentary (1296 words)

Notes:

1) BACKGROUND

The guidance letter involves a case in which a U.S. person with a judgment against the Government of Venezuela (GoV) sought to enforce the judgment by attaching real property (the “Subject Property”) located in the U.S. that was owned by an entity blocked pursuant to EO 13850. More specifically, the property was blocked due to it being owned by a blocked entity that was owned by Raul Gorrin Belisario, an individual blocked pursuant to EO 13850. Gorrin was blocked pursuant to EO 13850 for his involvement in a “currency exchange network which was another illicit scheme that the Venezuelan regime had long used to steal from its people”. According to an indictment linked in the OFAC press release announcing Gorrin’s designation, “Raul Gorrin Belisario, 50, and other co-conspirators in exchange for using his position as Venezuelan national treasurer...