LICENSE No. VENEZUELA-EO13850-2021-873266-1

Date issued: Jun. 22 2022

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TURBOFAC Commentary (757 words)

Notes:

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...