LICENSE No. VENEZUELA-2018-355407-2

Date issued: Aug. 28 2019

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TURBOFAC Commentary (461 words)

Notes:

1) Compare LICENSE No. VENEZUELA-EO13850-2019-359725-3 (law firm representing sanctioned Venezuelans could “engage in transactions ordinarily incident and necessary to sell the Properties, and the Licensee [was] authorized to recover for itself, and/or reimburse third parties, from the proceeds of the sale of any of the Properties, any taxes, costs, or legal, administrative or other fees that are necessary and incident to the sale of any of the Properties, and place the remainder in a blocked account, as consistent with section 591.203 of the Venezuela Sanctions Regulations and reported to OFAC.”

This license is similar in substance, but issued to a bank seeking to foreclose on the blocked real property, rather than a representative of the owner of the blocked property. Note that in LICENSE No. VENEZUELA-EO13850-2019-359725-3, the licensee must place the “remainder” of the “proceeds” of a property sale...