Venezuela General License 9A

OFFICE OF FOREIGN ASSETS CONTROL

Executive Order 13808 of August 24, 2017

Imposing Additional Sanctions With Respect to the Situation in Venezuela

Executive Order 13850 of November 1, 2018

Blocking Property of Additional Persons Contributing to the Situation in Venezuela

GENERAL LICENSE 9A

Authorizing Transactions Related to Dealings in Certain Securities

(a) Except as provided in paragraph (f) of this general license, all transactions and activities prohibited by Section l(a)(iii) of Executive Order 13808 (E.O. 13808) or Executive Order 13850 (E.O. 13850) that are ordinarily incident and necessary to dealings in any debt (including the bonds listed on the Annex to this general license, promissory notes, and other receivables) of, or equity in, Petr6leos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (together, PdVSA securities), issued prior to August 25, 2017 (the effective date of E.O. 13808), are authorized, provided that any divestment or transfer of, or facilitation of divestment or transfer of, any holdings in such PdVSA securities must be to a non-U.S. person.

(b) The transactions and activities authorized in paragraph (a) include facilitating, clearing, and settling transactions to divest to a non-U.S. person PdVSA securities, including on behalf of U.S. persons.

(c) Except as provided in paragraph (f) of this general license, all transactions and activities prohibited by Section l(a)(iii) of E.O. 13808 or E.O. 13850 that are ordinarily incident and necessary to facilitating, clearing, and settling trades of holdings in the PdVSA securities referred to in paragraph (a) of this general license are authorized, provided such trades were placed prior to 4:00 p.m. eastern standard time on January 28, 2019.

(d) Except as provided in paragraph (f) of this general license, all transactions and activities prohibited by Section l(a)(iii) of E.O. 13808 or E.O 13850 that are ordinarily incident and necessary to the wind down of financial contracts or other agreements that were entered into prior to 4:00 p.m. eastern standard time on January 28, 2019, involving, or linked to, PdVSA securities issued prior to August 25, 2017 are authorized. This authorization is valid through 12:01 a.m. eastern standard time, March 3, 2019.

(e) Except as provided in paragraph (f) of this general license, all transactions and activities prohibited by Section 1(a)(iii) of E.O. 13808 or E.O. 13850 that are ordinarily incident and necessary to dealings in any bonds that were issued prior to August 25, 2017 (the effective date of E.O. 13808) by the following entities or any of their subsidiaries, are authorized:

• PDV Holdings, Inc.

• CITGO Holdings, Inc.

• Nynas AB

(f) This general license does not authorize:

(1) The unblocking of any property blocked pursuant to any part of 31 C.F.R. chapter V,

except as authorized by paragraphs (a), (c), (d), and (e);

(2) U.S. persons to sell PdVSA securities to, to purchase or invest in securities of, or to facilitate such transactions with, directly or indirectly, any person whose property and interests in property are blocked pursuant to E.O. 13850, including PdVSA and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, other than purchases of or investments in PdVSA securities (including settlement of purchases or sales that were pending on January 28, 2019) that are ordinarily incident and necessary to the divestment or transfer of PdVSA securities; or

(3) Any transaction that is otherwise prohibited under Executive Order 13850 of November 1, 2018, Executive Order 13835 of May 21, 2018, Executive Order 13827 of March 19, 2018, Executive Order 13808 of August 24, 2017, Executive Order 13692 of March 8, 2015, or any part of 31 C.F.R. chapter V, or any transactions or dealings with any blocked person other than the transactions described in paragraph (a) of this general license.

(g) Effective February 1, 2019, General License No. 9, dated January 28, 2019, is replaced and superseded in its entirety by this General License No. 9A.

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