LICENSE No. VENEZUELA-EO13850-2019-359725-3, 4. 5, 7

Date issued: Feb. 07 2024

Last substantive commentary amendment:
Apr. 18 2024

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TURBOFAC Commentary (4476 words)

Notes:

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