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The U.S. Treasury Department ("Treasury") Office of Foreign Assets Control ("OFAC") replaced two general licenses under Executive Orders 13808 and 13850 related to sanctions imposed "with respect to the situation in Venezuela." OFAC also revised three FAQs (see here, here and here) that explain the two general licenses.
Both of the revised general licenses make clear that, in most circumstances, U.S. persons are not authorized to purchase or invest in, or to facilitate the purchase of or investment in, certain bonds or securities, other than to make purchases or investments that are ordinarily incident and necessary to the divestment or transfer of holdings in such bonds and other securities.
General License ("GL") 3C, which replaces GL 3B, authorizes certain "transactions related to [the] provision of financing for, and other dealings in certain bonds," including specified "GL 3B Bonds" listed on an annex to the general license.
GL 9B, which replaces GL 9A, permits certain transactions related to dealings in securities issued by Petróleos de Venezuela S.A. ("PdVSA"), or any entity in which PdVSA owns a 50 percent or greater interest ("PdVSA securities").
GL 3C and GL 9B are effective immediately.
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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