LICENSE No. VENEZUELA-EO13850-2019-363328-1, 2, 3, 4

Date issued: Dec. 30 2022

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TURBOFAC Commentary (222 words)

Notes:

1) Read in conjunction with RDK-related LICENSE No. VENEZUELA-EO13850-2019-360301-1 and LICENSE No. VENEZUELA-EO13850-2019-360301-3. The license contained in this file are, like those licenses, essentially "facilitation" licenses, that allow the involvement of yet-to-be-named U.S. persons involved in transactions that may otherwise be outside the scope of OFAC's primary sanctions jurisdiction altogether.

2) PAYMENTS IN KIND

The first iteration of the license places no restrictions on the ways in which RDK/other Curaçao-based creditors of PDVSA/Isla could be paid by PDVSA/Isla. The second and third iterations have a condition that says "[t]he authorization in SECTION I does not authorize payment in the form of Venezuelan-origin petroleum and petroleum products that are not already located on the island." The fourth iteration has a condition that says "[t]he authorization in SECTION I does not authorize payment in the...