Venezuela General License 42 - Authorizing Certain Transactions Related to the Negotiation of Certain Settlement Agreements with the IV Venezuelan National Assembly and Certain Other Persons

Date issued: May. 01 2023

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TURBOFAC Commentary (1301 words)

Notes Common to FAQ # 1123, FAQ # 1124, FAQ # 1125 and Venezuela GL 42

On 5-1-23, OFAC issued FAQ # 1123, FAQ # 1124, FAQ # 1125 and Venezuela GL 42.

1) FAQ # 1123 reproduces part of the substance of DOJ Letter to Crystallex Court Special Master on Behalf of OFAC (April 2023). The FAQ articulates the OFAC "non-enforcement posture" (NEP), which applies retroactively and prospectively, to actions related to the "Sale Procedures Order with respect to certain shares in PDV Holding (PDVH) to satisfy a U.S. district court judgment confirming an arbitral award against Venezuela". A proposed Sale Procedures Order can be found at p. 406 of the Crystallex Docket File. The NEP articulated in this FAQ, which references Venezuela GL 42 and related