OFAC FAQ (Removed) # 809 - Venezuela-related

Date issued: Dec. 09 2019

Last substantive commentary amendment:
May. 10 2023

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TURBOFAC Commentary (1837 words)

Notes:

1) BACKGROUND

This FAQ, issued concurrently with the original version of FAQ # 808, was an apparent reaction to attempts of judgment creditors of the Government of Venezuela, in particular the only entity that held a writ of attachment at the time of issuance, i.e. Crystallex International Corporation, to have the District Court for the District of Delaware issue a "Sales Procedure Order" that would pave the way for the ultimate judicial sale of blocked shares of a subsidiary of PDVSA. (See also the original version of FAQ # 808, specifying that “a specific license from OFAC would be required for measures such as…Selling (Final or Contingent),” with respect to blocked property.

Here, the question is “I hold a writ of attachment on shares of a Government of Venezuela entity whose property and interests in property are blocked pursuant to the...