LICENSE No. VENEZUELA-EO13850-2019-359725-1

Date issued: May. 22 2022

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TURBOFAC Commentary (255 words)

Notes:

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,...