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LICENSE No. VENEZUELA-EO13884-2022-919533-1
VENEZUELA SANCTIONS REGULATIONS
LICENSE
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, and 13884, and 31 C.F.R. Parts 501 and 591.
To: Anschütz GmbH
Zeyestrasse 16 -24
D-24106 Kiel
Germany
Attn: Stefan Kohler
1. Based upon the request dated May 31, 2022, additional correspondence dated February 28, 2023, September 21, 2023, September 29, 2023, and September 6, 2024, to the Office of Foreign Assets Control (the “Application”), and additional information otherwise available to the Office of Foreign Assets Control, 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,...
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1) Geneal Factual Background
As described in the PDF (see pp. 2-8), the German subsidiary (Anschütz) of a U.S. person entity lost an ICC arbitration in 2012 to an entity that meets the definition of “Government of Venezuela” and is owned by PdVSA (“DIANCA”). The arbitral award was conditioned on DIANCA dismissing its parallel litigation against Anschütz in Venezuela, and in 2016, Anschütz entered into an escrow agreement with JPMorgan whereby it deposited $4,018,247 into an escrow account that provided that Anschütz retained ownership of the funds, and that the funds would remain in escrow until such time as Anschütz certified that the conditions of the arbitral award (e.g. dismissal of the Venezuela litigation) were satisfied. The escrow agreement explicitly stated that DIANCA was not a party thereto. “DIANCA secured dismissal of the Venezuelan litigation in April of 2018, at which point Anschütz’s...