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LICENSE No. VENEZUELA-EO13850-2020-367941-1
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, and 13835, 13850, 13857. 13884 and 31 C.F.R. Parts 501 and 591.
To: Fisher Island Condominium Association, Inc.
c/o Ferrari & Associates, P.C.
1455 Pennsylvania Ave., N.W.
Suite 400
Washington, D.C. 20004
Attn: Peter Kucik
1. Based upon your request dated July 7, 2020 to the Office of Foreign Assets Control (the "Application"), and information otherwise available 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 terms and with all regulations, rulings, orders, and instructions issued under...
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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...