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Case No. LI2-579
Oilinvest (Netherlands) B.V.
Wolweverstraat 23-25
2984 CE Ridderkerk
P.O. Box 4088, 2980 GB Ridderkerk
THE NETHERLANDS
Attn: A. Sozonoff, Director
Dear Mr. Sozonoff:
This responds to your letter of September 2, 2011, to the Office of Foreign Assets Control (“OFAC”), on behalf of Oilinvest (Netherlands) B.V. (“ONBV”) and its subsidiaries (collectively, the “Tamoil Group”), for confirmation that U.S. persons, including financial institutions and other service providers, are authorized to transact with and to receive and make payments to and from the Tamoil Group. In addition, you request confirmation that OFAC will authorize U.S. financial institutions to unblock blocked payments involving the Tamoil Group.
On February 25, 2011, the President signed Executive Order (E.O.) 13566, “Blocking Property and Prohibiting Certain Transactions Related to Libya.” The E.O. imposed far-reaching sanctions...
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1) See Libya - General License No. 7a, which states that “[a]ll transactions involving the Libyan National Oil Corporation (NOC) or entities owned or controlled by the NOC are authorized…[t]his authorization includes, but is not limited to, the following NOC subsidiaries… Tamoil Group…”
One notable aspect of the guidance letters is that “Tamoil Group” (described in the GL as one of several listed “entities”) was interpreted to include “Oilinvest (Netherlands) B.V…and its subsidiaries”.
Also notable is that the request for guidance was made on September 2, 2011, which was immediately after reports of the Government of Libya shares in Oilinvest being put in “an independent foundation” known as a “Stichting”. The purpose of this was to comply with EU sanctions on Libya, i.e. by severing formal ownership and control of the shares...