LICENSE No. VENEZUELA-2019-363495-1

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (645 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, 13884). As it relates...

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LICENSE No. VENEZUELA-2019-363495-1

TURBOFAC Commentary (645 words)