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DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
LICENSE No. VENEZUELA-2018-355407-2
VENEZUELA SANCTIONS REGULATIONS
AMENDED LICENSE
(Granted under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, Pub. L. 113-278, Executive Orders 13692, 13808, 13827, and 13835, and 31 C.F.R. Parts 501 and 591.)
To: Wells Fargo & Co.
Global Sanctions Governance Group
401 S. Tryon St. - 26th Floor MAC: Dl0S0-262
Charlotte, NC 28202
Attn: Lorraine B. Lawlor
1. Based upon your request dated August 6, 2019 to the Office of Foreign Assets Control (the "Application"), the transactions described herein are hereby authorized. License Number Venezuela-2018-355407-1 is replaced and superseded in all respects.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with...
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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...