Case No. VENEZUELA-EO13884-2023-1057131-1, License No. VENEZUELA-EO13884-2023-1057131-1

Date issued: May. 04 2023

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TURBOFAC Commentary (1216 words)

Notes:

1) BACKGROUND

This is an extremely rare specific license, rare in that it is issued to a U.S. federal court, and also rare in that it is issued sua sponte, i.e. not in response to an "application".

The issuance of the specific license and associated transmittal letter were done on the same day as OFAC's May 1, 2023 indirect intervention in the long-running Crystallex case referenced in the transmittal letter, in which OFAC, among other things published FAQ # 1123, specifying that it would take a "non-enforcement posture" vis-à-vis any person "participating in, facilitating, or complying with the prefatory steps set out in the [Crystallex] court’s Sale Procedures Order" found at p. 782 of the Crystallex Docket File.

As discussed in detail in Consolidated Comment on Crystallex International Corporation v. Bolivarian Republic of Venezuela (D. Del, 2017...