ARTICLE
7 November 2019

OFAC Replaces Venezuela-Related General License

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Cadwalader, Wickersham & Taft LLP

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On October 24, 2019, OFAC replaced and superseded a General License clarifying certain transactions regarding any equity interest in an entity owned 50 percent or more by the Venezuelan government.
United States International Law
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On October 24, 2019, OFAC replaced and superseded a General License clarifying certain transactions regarding any equity interest in an entity owned 50 percent or more by the Venezuelan government. OFAC also updated Frequently Asked Question 595 on the issue.

According to OFAC, General License 5A was implemented to allow certain transactions on or after January 22, 2020, that involve the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond that otherwise would be prohibited under Executive Order 13835 ("Prohibiting Certain Additional Transactions With Respect to Venezuela"). In its updated FAQ, OFAC highlighted the delay in effectiveness of the amended General License, and noted that before January 22, 2020, "transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC."

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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