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License No. VENEZUELA-2018-353747-1
LICENSE No. VENEZUELA-2018-353747-1
VENEZUELA SANCTIONS REGULATIONS
LICENSE
Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, Pub. L. 113-278, Executive Order 13692, Executive Order 13808, Executive Order 13827, Executive Order 13835, and 31 C.F.R. Parts 501 and 591.
To: ConocoPhillips Company
600 North Dairy Ashford
Houston, TX 77079
Attn: Jennifer D. Hardin
1. Based upon your request dated May 27, 2018, and additional correspondence dated July 9, 2018, July 18, 2018, and July 19, 2018 to the Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and...
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1) BACKGROUND; CHRONOLOGY
The two specific licenses, License No. VENEZUELA-2018-353747-1 (July 24, 2018) and LICENSE No. VENEZUELA-2018-353747-2 (an amended version of -1 (April 25, 2019)), were produced in the context of litigation arising from a default, by the Venezuelan state-owned oil company “PDVSA,” on debts owed to two Venezuelan subsidiaries of ConocoPhillips, a U.S. person oil & gas company. More specifically, ConocoPhillips was issued an arbitral award on April 24, 2018, in an arbitration held by the International Chamber of Commerce (ICC). Prior to a substantive discussion of the two licenses included in this file, we lay out a chronological timeline of notable events below (in part as recounted by the plaintiffs to the lawsuit in the attached .pdf file):
(i) August 25, 2017 – Issuance of Executive Order 13808, which prohibits transactions involving “new debt with a maturity of greater than...