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LICENSE No. VENEZUELA-2019-358982-1
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 Orders 13692, 13808, 13827, 13835, 13850, and 13857, and 31 C.F.R. Parts 501 and 591.
To: PDVSA Services, Inc.
c/o [ ]
1101 Seventeenth Street, N.W., Suite 1100
Washington, DC 20036
Attn: [ ]
[ ]
1. Based upon the request dated February 1, 2019 and supplemental information dated February 9, 2019 and February 11, 2019 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 instructions issued under one...
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1) PDVSA Services Inc. is/was wholly owned by PdVSA, hence the need for the license (see p. 2 of https://www.justice.gov/opa/press-release/file/1033901/download). This specific license is most notable for the specific licensing policy—not otherwise discernible from OFAC regulations or other statements—as it relates to U.S. entities owned or controlled by PdVSA. It is rare that OFAC allows the unblocking of accounts (compare generally General Note on, and Notable Examples of, Specific Licenses Issued Pursuant to Unwritten Licensing Policies). Here, the unblocking license allows for payments of "salaries, expenses, and severance packages to employees and contractors; service providers; and contract obligations".
2) The license implicitly interprets the phrase “ordinarily incident and necessary to the wind down of [] operations,” which appears in many GLs. It is clear that payments related to "salaries, expenses, and severance packages to employees and...