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LICENSE No. VENEZUELA-EO13850-2018-358633-1
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: Rothwell Energy Services, LLC
c/o [ ]
2001 K Street, NW
Washington, DC 20006
Attn: [ ]
1. Based upon the request dated November 26, 2018, additional correspondence dated July 26, 2019, November 7, 2019, and April 12, 2021, and information otherwise available to the Office of Foreign Assets Control (the "Application"), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and...
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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.”...