Date: January 31st 2020

To the Board of Directors

Vikua Inc | Global CTL
8 The Green, Suite # 5263,
Dover, DE 19901, USA

Dear Sir/Madam

RE: LEGAL OPINION ABOUT THE DEPARTMENT OF THE TREASURY - OFFICE

OF FOREIGN ASSETS CONTROL. UNITED STATES OF AMERICA

1.0 INTRODUCTION

We, the undersigned Advocates are rendering this Legal Opinion in compliance with
your letter of instructions dated January 28th 2020, bearing Reference No: VKA-2021-
01, in which you duly informed us that you would like to have a comprehensive analysis
regarding the US Imposed Sanctions over the Government of the Bolivarian Republic of
Venezuela and your current business on Venezuelan territory.

Secondly, that you wish to be notified of the existence of legislation if any, on the issue
of providing technology, telecommunications, and other product and services to entities
from the public and private sectors, especially under the current Global Pandemic of
COVID-19.

2.0 ABOUT GENERAL LICENSES

The following are GLs issued by OFAC related to humanitarian assistance and trade
with Venezuela.

• General License 4C
https://home.treasury.gov/system/files/126/venezuela_gl4c.pdf
Authorizes certain transactions ordinarily incident and necessary to the exportation or
re-exportation of agricultural commodities, medicine, medical devices, replacement
parts and components for medical devices, or software updates for medical devices to
Venezuela, or to persons in third countries purchasing specifically for resale to
Venezuela. This includes testing kits, respiratory devices, personal protective
equipment, and medicine used in the prevention, diagnosis, treatment, and recovery
from COVID-19.

• General License 16C

https://home.treasury.gov/system/files/126/venezuela_gl16c.pdf
Authorizes all transactions and activities ordinarily incident and necessary to
processing noncommercial, personal remittances involving certain financial
institutions, including Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela),
Banco Bicentenario del Pueblo, de la Clase Obrera, Mujer y Comunas, Banco Universal
C.A. (Banco Bicentario del Pueblo), Banco del Tesoro, C.A. Banco Universal (Banco del
Tesoro), and Banco Central de Venezuela (BCV). In addition, remittances with non-
blocked Venezuelan financial institutions are not prohibited.
• General License 20B
https://home.treasury.gov/system/files/126/venezuela_gl20b.pdf
Authorizes official activities of certain international organizations such as the United
Nations, including its Programmers and Funds, and its Specialized Agencies and
Related Organizations, as well as the International Committee of the Red Cross, among
others, to engage in transactions involving BCV, or involving other Government of
Venezuela persons to the extent the transactions are subject to U.S. jurisdiction.

• General License 26
https://home.treasury.gov/system/files/126/venezuela_gl26.pdf
Authorizes the provision and receipt of nonscheduled emergency medical services and
the provision of other medical services involving the Government of Venezuela.

• General License 29
https://home.treasury.gov/system/files/126/venezuela_gl29.pdf
Authorizes non-governmental organizations to engage in transactions involving the
Government of Venezuela in support of humanitarian projects, democracy building,
education, non-commercial development projects directly benefiting the Venezuelan
people, and environmental protection in Venezuela.

• General License 30
https://home.treasury.gov/system/files/126/venezuela_gl30.pdf
Authorizes activities involving the Government of Venezuela that are ordinarily
incident and necessary to operations or use of ports and airports in Venezuela.

• General License 33
https://home.treasury.gov/system/files/126/venezuela_gl33.pdf
Authorizes, among other activity, all transactions involving the Government of
Venezuela necessary to provide air ambulance and related medical services, including
medical evacuation from Venezuela, for individuals in Venezuela.

3.0 OPINION:

Having examined the relevant legislation and information, we are of the opinion that
according to the General Licenses (Gls) issued by the Department Of The Treasury -
Office Of Foreign Assets Control - United States Of America your company is working
in compliance with their guidelines and under the generally accepted practices of
business according to the US Laws.

This opinion is limited to matters requested by you on behalf of your company and may
not be read as extending by implication to any matters not specifically referred to.

Nothing in this opinion should be taken as expressing an opinion in respect of any

representations or warranties or other information, or any other document examined in
connection with this opinion except as expressly confirmed herein.
This opinion is addressed to you solely for the benefit of Vikua Inc and Global CTL alone
and may not be relied upon, used by, or shown to any other person or for any other
purpose.

We hereby opine and advise.

Respectfully,

Derek Plohm
…………………………
Attorney at law

CC:
Mr Rafael Franco – Chairman of the board
Vikua Board of Directors
Global CTL Board of Directors