LICENSE No. VENEZUELA-2018-353747-1, LICENSE No. VENEZUELA-2018-353747-2, LICENSE No. VENEZUELA-2018-353747-4

Date issued: Aug. 21 2020

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TURBOFAC Commentary (1982 words)

Notes:

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...