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LICENSE No. VENEZUELA-2019-363495-1
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, 13835, 13850, 13857, and 13884, and 31 C.F.R. Parts 501 and 591.
To: Teknik Trading LLC
c/o The Volkov Law Group LLC
2200 Pennsylvania Avenue, NW
4th Floor East
Washington, DC 20037
Attn: Michael Volkov
1. Based upon your request dated October 3, 2019, as supplemented on February 9, 2021, 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,...
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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...