License No. VENEZUELA-EO13884-2022-975232-1

Date issued: Nov. 21 2022

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TURBOFAC Commentary (867 words)

Notes:

(I) Background

Read in conjunction with the surrounding documents contained in the native PDF file, this license is notable for a few reasons. First note the timeline of relevant events:

(i) Oct 2, 2019 - JPMorgan (JPM) accountholder Corporacion Industrial de Energía C.A (CIE) is identified as a "potential sanctions match" through JPM third-party screening tool (p. 65). [Note that CIE is a Venezuelan entity that was incorporated in 1999, held the account at JPM since 1999 (p.3) , operated/operates in the energy/electricity sector of Venezuela and is traded on a small Venezuelan stock exchange (https://es.wikipedia.org/wiki/Bolsa_de_Valores_de_Caracas)].

(ii) Oct. 3, 2019 – JPM internally "escalated the match for further review and handling" (p. 65)

(iii) Nov 6, 2019 - "the account was blocked pursuant to the [VSR] as JPM identified [CIE] as a ‘Venezuelan state-controlled entity’” (id.)
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