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LICENSE No. VENEZUELA-EO13850-2019-359725-7
VENEZUELA SANCTIONS REGULATIONS
LICENSE EXTENSION
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: Lankford & Reed PLLC
120 N. St. Asaph Street
Alexandria, VA 22314
Attn: D.E. Wilson, Jr.
1. Based upon your request dated February 14, 2024, to the Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized. License No. VENEZUELA- EO13850-2019-359725-5 is replaced and superseded in all respects.
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...
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The below addresses aspects of the license in isolation, as well as aspects of the license in relation to the complex litigation of which it was offered as an exhibit. The timeline of relevant events is set out below, with all references to page numbers referring to the native PDF file. See the first iteration of this license at LICENSE No. VENEZUELA-EO13850-2019-359725-1.
1) Background: Timeline of Key Events
Aug 16, 2019 – Raul Belisario Gorrin made subject to a sealed indictment in U.S. court for activities related to money laundering and corruption. Gorrin was (as of 12/12/2021) a fugitive residing in Venezuela (https://www.justice.gov/usao-sdfl/pr/former-venezuelan-national-treasurer-and-her-spouse-charged-connection-international).
January 8, 2019 – Gorrin, Gustavo Perdomo (Perdomo) and Mayela Antonina Tarascio Perez, the former wife of Perdomo, were designated as SDNs, pursuant to