LICENSE No. VENEZUELA-EO13850-2019-360364-5, 6, 7

Date issued: May. 11 2023

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TURBOFAC Commentary (406 words)

Notes:

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...