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LICENSE No. VENEZUELA-EO13850-2020-367941-2
VENEZUELA SANCTIONS REGULATIONS
LICENSE AMENDMENT
(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, 13884 and 31 C.F.R. Parts 501 and 591.)
To: Palazzo Del Sol/Della Luna at Fisher Island Condominium Association, Inc.
c/o Michael E. Chapnick, Esq.
Sachs Sax Caplan, P.A.
6111 Broken Sound Parkway, Suite 200
Boca Raton, FL 33487
1. Based upon the request dated July 7, 2023, on behalf of Palazzo Del Sol/Della Luna at Fisher Island Condominium Association, Inc. to the Office of Foreign Assets Control, the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee complies with its...
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1) The license suggests that the mere filing of an "in rem action for lien foreclosure" requires an OFAC license. Compare generally General Note Concerning Unlicensed Litigation Involving Sanctioned Persons or Property; the Question of Whether Judicial Action Constitutes the Unlicensed "Transfer" of Blocked Property (System Ed. Note). Is a license required for in rem litigation where the activities do not require a "transfer" of the blocked property? It is possible that OFAC asserts jurisdiction over in rem proceedings due to an assumption that the initiation of such proceedings will quickly result in an attempt to arrest, or judicially restrain, the blocked property in question. Compare LICENSE No. FNK-2017-340944-2 (the...prohibition on United States persons’ transactions or dealings in blocked property [applies] to the arrest and transfer of custody of [blocked] vessels" by a court). OFAC has considered such actions to...