August 25, 2017: OFAC kicks it up a notch on Venezuela

On Friday, President Trump issued a new Executive Order imposing a new set of prohibited transactions regarding Venezuela:

 

(i) new debt with a maturity of greater than 90 days of Petroleos de Venezuela, S.A. (PdVSA);
(ii) new debt with a maturity of greater than 30 days, or new equity, of the Government of Venezuela, other than debt of PdVSA covered by subsection (a)(i) of this section;
(iii) bonds issued by the Government of Venezuela prior to the effective date of this order;
(iv) dividend payments or other distributions of profits to the Government of Venezuela from any entity owned or controlled, directly or indirectly, by the Government of Venezuela.
(b) The purchase, directly or indirectly, by a United States
person or within the United States, of securities from the Government of Venezuela, other than securitiEs qualifying as new debt with a maturity of less than or equal to 90 or 30 days as covered by subsections (a)(i) or (a)(ii) of this section, respectively, is prohibited.

Mr. Watchlist expects a new set of SSI-like designations for PdVSA and elements of the Government of Venezuela in short order. Compliance officers need lists…

In addition, four Generali Licenses were issued:

General License 1: Authorizing Certain Activities Necessary to Wind Down Existing Contracts

General License 2: Authorizing Certain Transactions Involving CITGO Holding Inc., 

General License 3: Authorizing Transactions Related to, Provision of Financing for, and Other Dealings in Certain Bonds

General License 4: Authorizing New Debt Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, or Replacement Parts and Components

Lastly, OFAC added some Frequently Asked Questions…. you’ll see us post them in a series of posts.

Links:

OFAC Notice

Executive Order

General License 1, 2, 34

FAQ

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