U.S. persons are generally prohibited from engaging in transactions or dealings with persons named on OFAC’s SDN List, including dealing with an SDN in the context of efforts to restructure Venezuelan and Petroleos de Venezuela, S.A. (PdVSA) debt. Provided there is no SDN involvement, Venezuela-… Read more
Yes. For purposes of E.O. 13808 , the prohibition in Subsection 1(a)(i) would apply to PdVSA and extend to all PdVSA subsidiaries, unless authorized by OFAC. Note that General License 2 authorizes certain activities involving specified PdVSA …
The term debt includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper. The term equity includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership. The… Read more
OFAC considers “new debt” to be debt created on or after August 25, 2017. See FAQ 511 for examples of “debt,” which includes loans and extensions of credit. OFAC does not consider debt that was created prior to August 25, 2017 to be “new debt” for purposes of E.O. 13808 so long as the terms of the… Read more
The Government of Venezuela is selling assets for much less than they are worth at the expense of the Venezuelan people and using proceeds from these sales to enrich supporters of the regime. Bonds and other securities are among the assets being sold. The prohibitions and related general licenses… Read more
In general, yes. These prohibitions apply to transactions related to the Government of Venezuela, which is defined in E.O. 13808 to include all entities owned or controlled by the Government of Venezuela. This would normally include entities owned 50 percent or more by the Government of Venezuela… Read more
No, absent a specific license or other authorization from OFAC. As explained in FAQ 553 , debt – which includes extensions of credit for sales of goods or services – created on or after August 25, 2017 constitutes “new debt,” and E.O. 13808 prohibits U.S. persons and persons within the United… Read more
Absent authorization from OFAC, U.S. persons are prohibited from engaging in transactions related to, providing financing for, and otherwise dealing in any “digital currency, digital coin, or digital token” that was issued by, for, or on behalf of the Government of Venezuela on or after January 9,… Read more