524. I would like to engage in derivatives transactions, including credit default swaps, related to a reference bond that is in the Annex to General License 3. Is that permitted?

Paragraphs (a) and (b) of General License 3 (this content is no longer available) authorize all transactions related to, the provision of financing for, and other dealings in bonds that are either listed in the Annex to General License 3 or 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 (“General License 3 bonds”). Buying, selling, or otherwise dealing in a derivative that references a General License 3 bond is a transaction related to the bond itself. General License 3 therefore authorizes such purchases and sales, as well as related transactions. One corollary to this authorization is that U.S. persons are not authorized to buy, sell, or otherwise deal in derivatives that reference bonds that (i) were issued by the Government of Venezuela prior to August 25, 2017, but (ii) are not General License 3 bonds.