LICENSE No. VENEZUELA-2019-363495-1

Date issued: Feb. 18 2021

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (633 words)

Notes:

1) This relatively recently issued license may illustrate a favorable licensing policy with respect to the collection, by U.S. persons, of accounts receivable where (i) PDVSA is the debtor, (ii) the payments come out of “fresh funds,” and (iii) the underlying activity is connected to activity that pre dates the otherwise applicable sanctions prohibitions.

Here, the facts surrounding the license are described by the Citgo and the licensee in the filings included in the native PDF file. They disagree on much, but there seems to be no dispute that the OFAC license relates to the storing of unspecified liquid goods (presumably some sort of petroleum product or other petrochemical) that were procured by the U.S. person licensee Teknik, for PDVSA, prior to the blocking of PDVSA pursuant to EO 13850 (and, later on, EO 13884). As it relates...