Case No. VENEZUELA-EO13850-2019-361482-1
[ ], Esq.
[ ]
2665 S. Bayshore Drive, Suite 200
Miami, FL 33133
Dear Mr. [ ]:
This letter responds to your correspondence dated June 11, 2019 to the Office of Foreign Assets Control (OFAC) (the “Application”) on behalf of ICM Proyectos 2001 C.A. (“ICM”), requesting a specific license to continue to provide services to Petropiar, S.A. , an oil upgrader operating in Venezuela’s Orinoco Belt, owned jointly by Petroleos de Venezuela, S.A. (“PdVSA”) and Chevron Corporation (30%) under a contract called “Reinforcement of the walls of Coke Drums 12-v-0031004 with Inconel (weld overlay) for Petropiar upgrader” (the “Contract”). You're requesting a specific license because you anticipate that the provision of services under the Contract will extend beyond the July 27, 2019 expiration of OFAC’s Venezuela General License 8A.
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1) The applicant requests a specific license to “continue to provide services to Petropiar, S.A…[an entity] owned jointly by [PdVSA] and Chevron Corporation (30%)…”
OFAC determines that “In light of the authorization in General License 8C no specific authorization is required for [the Applicant] to perform under the terms of the Contract [with Petropiar] until October 25, 2019” (which is the expiration date of GL 8C).
Venezuela Venezuela GL 8C (and other iterations) authorized “certain otherwise prohibited “transactions and activities…that are ordinarily incident and necessary to the limited maintenance of essential operations, contracts, or other agreements, that: (i) are for safety or the preservation of assets in Venezuela; (ii) involve PdVSA or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest; and (iii) were in effect prior...