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LICENSE No. VENEZUELA-EO13850-2021-873266-1
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, 13884, and 31 C.F.R. Parts 501 and 591.
To: PDV Holding, Inc.
CITGO Petroleum Corporation
c/o Willkie Farr & Gallagher LLP
1875 K Street, N.W.
Washington, DC 20006-1238
Attn: David Mortlock
1. Based upon the request dated October 11, 2021, and additional correspondence dated November 15, 2021, (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 Licensees comply with its terms and with all regulations, rulings, orders, and instructions issued under any...
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1) As is evident form the first three pages of the PDF file, the netting and offset agreement that is the subject of the specific license was entered into between U.S. person subsidiaries of PdVSA and the “Ad Hoc Administrative Board of” PdVSA (i.e. PdVSA as controlled by “National Assembly” recognized by the U.S. as the legitimate government of Venezuela, rather than the government in Caracas led by Nicolas Maduro). The “license” are the U.S. persons CITGO and its Delaware holding company PDV Holding Inc. The license was issued “to the extent authorization is required”. Why might that be, since the U.S. persons, which themselves are blocked, would clearly be dealing in blocked debts owed to PdVSA? Venezuela General License 7C authorizes all transactions “with respect to PDV Holding, Inc. (PDVH), CITGO Holding, Inc., and any of their subsidiaries…where the only Government of Venezuela...