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LICENSE No. VENEZUELA-EO13850-2019-359725-1
VENEZUELA SANCTIONS REGULATIONS
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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: Venable LLP
600 Massachusetts Avenue, N.W.
Washington, D.C. 20001
Attn: D.E. Wilson, Jr.
1. Based upon your request dated March 6, 2019 and additional correspondence dated July 19, 2019, 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.
3. This License expires on...
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1) This license is notable primarily for the way in which it compares to LICENSE No. VENEZUELA-EO13850-2019-359725-3, which is a much broader license that covers similar subject matter.
The primary differences between the two licenses are (i) the blocked property at issue, (ii) the fact that LICENSE No. VENEZUELA-EO13850-2019-359725-3 has an authorization for "representing the Properties in litigation and other forms of dispute resolution," which implies that this activity was not authorized by the first iteration of the license. See comments to LICENSE No. VENEZUELA-EO13850-2019-359725-3. OFAC may be of the view that the standard legal services GL, which applies on its face to "[t]he provision of [...] legal services to or on behalf of persons whose property and interests in property are blocked," does not extend to the representation of blocked property,...