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LICENSE No. VENEZUELA-EO13850-2019-363328-4
VENEZUELA SANCTIONS REGULATIONS
LICENSE EXTENSION
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: Refineria di Korsou N.V.
c/o Gibson, Dunn & Crutcher LLP
1050 Connecticut Avenue, NW
Washington, DC 20036
Attn: Adam M. Smith
1. Based upon the request dated December 1, 2022, on behalf of Refineria di Korsou N.V., and information otherwise available to the Office of Foreign Assets Control (the "Application"), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and...
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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...