ARTICLE
4 January 2021

OFAC Modifies Authorizations Under Venezuela- And Ukraine-Related General Licenses

CW
Cadwalader, Wickersham & Taft LLP

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OFAC authorized certain transactions related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond, which otherwise would be prohibited by Executive Order.
Worldwide International Law
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OFAC authorized certain transactions related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond, which otherwise would be prohibited by Executive Order 13835 ("Prohibiting Certain Additional Transactions With Respect to Venezuela"). OFAC specified that General License ("GL") 5F does not authorize any transactions otherwise prohibited by the Venezuela Sanctions Regulations.

GL 5F supersedes GL 5E (see previous coverage here), and as described in updated FAQ 595, delays the date of effectiveness until July 21, 2021.

Additionally, OFAC extended the expiration date for two Ukraine-related GLs through January 26, 2022 (see previous coverage here):

  • GL 13P, which supersedes GL 13O, authorizes certain transactions necessary to divest or transfer holdings in GAZ Group which otherwise would be prohibited by the Ukraine Related Sanctions Regulations; and
  • GL 15J, which supersedes 15I, authorizes activities necessary to the maintenance or wind down of operations and contracts involving GAZ Group.

Primary Sources

  1. OFAC General License 5F: Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 21, 2021
  2. OFAC FAQ: Venezuela Sanction - 595
  3. OFAC General License 13P: Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group
  4. OFAC General License 15J: Authorizing Certain Activities Involving GAZ Group

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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