OFAC FAQ (Current) # 808 - Venezuela-related (PDF Contains All Versions)

Date issued: May. 01 2023

Last substantive commentary amendment:
Feb. 21 2024

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TURBOFAC Commentary (1903 words)

Notes

1) The original version of FAQ # 808, which was issued on 12-09-2019 concurrently with the now-removed FAQ # 809, was an apparent reaction to attempts of judgment creditors of the Government of Venezuela to have the District Court for the District of Delaware issue writs of attachment (actual and/or “conditional”) on blocked shares of an entity owned by PDVSA, and for the issuance of a "Sales Procedure Order" that would pave the way for the ultimate judicial sale of blocked shares for which an actual writ of attachment (see Crystallex Int'l Corp. v. Bolivarian Republic of Venez., 333 F. Supp. 3d 380 (D. Del. 2018)) that had already been granted. See also FAQ # 809 with respect to OFAC's initial view of the relationship between the blocking prohibition and the prospect of there being a Sales Procedure Order.

The original FAQ,...