License No. VENEZUELA-EO13850-2020-369648-1
Alfonso Montoya
Italbank International, Inc.
33 Bolivia St., Suite 1A
San Juan, PR 00917
Reference is made to the following blocked bank account:
Account Holder: South American International Bank Curacao N.V.
Account Number: 100000416
Value Date: 06/12/2019
Amount: $4,359,746.92
Italbank International, Inc. blocked $4,359,746.92 in this account pursuant to U.S. sanctions administered by the Office of Foreign Assets Control (OFAC). OFAC has carefully reviewed the information presented and otherwise available to it in connection with this account and has determined that Italbank International, Inc. is authorized to unblock $4,359,746.92 in the account noted above.
Sincerely,
Mary Patricia Rasmussen
Deputy Assistant Director for Licensing
Office of Foreign Assets Control
[2024.12.13]
cc: Joseph S. Rosenbaum, Esq....
1) Background
As described in the application (see PDF), the non-U.S. person bank applicant had a correspondent account with a U.S. person bank, and that account was used to process transactions in which, unbeknownst to the non-U.S. person bank, a blocked person (PdVSA) likely had an interest. Here, the $4,359,746.92 blocked by the U.S. person bank reflected an amount of money that, spread across several wires made over a two-month period (see p. 19, PDF), was equal to the amount of unlawful wire transfers that had been processed through the correspondent bank.
The applicant non-U.S. person bank represented that the customer of the applicant non-U.S. person bank who received the otherwise blockable wire transfers had transferred them out of the account that was related to the correspondent account that was partially blocked prior to the U.S. person bank taking the blocking action, such...