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LICENSE No. VENEZUELA-EO13850-2022-947074-1
VENEZUELA SANCTIONS REGULATIONS
LICENSE
Granted 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: Cristobal3 Partners LLC
c/o Greenberg Traurig LLP
2101 L Street, NW, Suite 1000
Washington, D.C. 20037
Attn: Kara M. Bombach
1. Based upon the request dated March 21, 2022 on behalf of Cristobal3 Partners LLC, 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 instructions issued under any of the authorities cited above....
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1) For relevant factual background concerning related case, see comments to LICENSE No. VENEZUELA-EO13850-2019-359725-3.
2) This license is notable, and rare, for the way in which it attempts to (and does) “cure” an otherwise unlicensed dealing in property in which a blocked person had an interest. Specifically, it appears that U.S. persons purchased the yacht Blue Ice at a time at which a blocked person had an interest therein (see comments to LICENSE No. VENEZUELA-EO13850-2019-359725-3). The license, issued on July 1, 2022, attempts to “cure” the otherwise unauthorized purchase, and make it such that the purchase would not be “null and void” for the purposes of U.S. law. (See General Note on the Boilerplate Provision Titled “Effect of Transfers Violating the Provisions of This Part”; “Null and Void” Transfers (System Ed. Note)). Compare Case...