LICENSE No. VENEZUELA-EO13850-2018-358633-1

Date issued: Oct. 08 2021

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TURBOFAC Commentary (162 words)

Notes:

1) Read in conjunction with Case No. VENEZUELA-EO13850-2018-358633-1 (cover letter) and Case No. VENEZUELA-2018-358633-1 (prior interpretive guidance letter). From a licensing policy perspective, this license is relatively consistent with other specific licenses authorizing the collection of funds owed to U.S. persons prior to the blocking of PDVSA. Compare LICENSE No. VENEZUELA-2019-363495-1.

2) The license authorizes a U.S. person to engage in “all transactions necessary to collect and receive payments from [CITGO and PdVSA],” both of which are blocked, but a condition of the license is that it “does not authorize any exportation or reexporation of any goods, services, or technology, directly or indirectly, by U.S. persons, wherever located, or from the United States, to PdVSA or any entity owned 50 percent or more, directly or indirectly, by PdVSA, or to any other blocked persons.”...