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LICENSE No. VENEZUELA-EO13850-2019-360364-7
VENEZUELA SANCTIONS REGULATIONS
LICENSE EXTENSION
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, 13857, and 13884, and 31 C.F.R. Parts 501 and 591.
To: Monómeros Colombo Venezolanos, S.A.
c/o Greenberg Traurig, LLP
2101 L Street, NW, Suite 1000
Washington, DC 20037
Attn: [ ]
1. Based upon the request dated January 27, 2023, and additional information available to the Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized. This License replaces and supersedes License number VENEZUELA-EO13850-2019-360364-6 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) See first iteration at LICENSE No. VENEZUELA-EO13850-2019-360364-1. The only difference between the 5th, 6th and 7th iterations are the expiration dates.
2) This license, of which version 7 is valid through May 11, 2023, licenses against the entirety of the VSR as it exists as of 7-16-23. Note that the license specifically names "50 percent or more owned subsidiaries" of Monomeros Colombo Venezolanos, S.A. that were not included in the first specific license. The implication appears to be that transactions of subsidiaries of Monomeros Colombo Venezolanos, S.A. were not covered by the initial license, except insofar as they were ordinarily incident to transactions with Monomeros Colombo Venezolanos, S.A.
3) This license is rare in two respects. First, it licenses against all of the VSR, even EO 13692, meaning that if a transaction involving Monomeros also included...