OFAC intentionally excluded the Venezuela Government International Bond issued on December 29, 2016 (ISIN USP97475AQ39, CUSIP AM1108092) (“the 2036 bond”) from the Annex to General License 3 because available information indicates that the Government of Venezuela is both the bond’s issuer and sole holder. At this time, the 2036 bond is the only bond we have identified and purposely omitted from the Annex to General License 3.
Parties who identify additional bonds that they believe should be added to the Annex to General License 3 should email OFAC at OFAC_Feedback@treasury.gov with information about the bond (including its ISIN, CUSIP, description, issuance date, maturity date, and prospectus/terms and conditions) and provide their rationale for adding it to the Annex (e.g., a party other than the Government of Venezuela holds the bond). No particular characteristics or circumstances will guarantee a bond’s addition to the Annex to General License 3; OFAC will evaluate each request on a case-by-case basis.
Paragraph (b) of General License 3 (this content is no longer available) authorizes all transactions related to, the provision of financing for, and other dealings in bonds that were issued both (i) prior to August 25, 2017, and (ii) by U.S. person entities owned or controlled, directly or indirectly, by the Government of Venezuela. Consequently, while bonds that meet both of these criteria may not be included in the Annex to General License 3, U.S. persons are nevertheless authorized to deal in these bonds