Frequently Asked Questions

663. Does the Secretary of the Treasury’s determination on March 22, 2019, that persons operating in the financial sector of the Venezuelan economy may be subject to sanctions pursuant to Executive Order 13850, as amended, mean that all Venezuelan financial institutions have been sanctioned by OFAC as of March 22, 2019, and are now blocked persons?

… those persons listed on OFAC’s SDN List, and entities that they own, directly or indirectly, 50 percent or more of, are blocked persons and subject to sanctions pursuant to E.O. 13580 , as … those persons listed on OFAC’s SDN List, and entities that they own, directly or… Read more

817. What is the significance of OFAC’s designations of Rosneft Trading S.A. and TNK Trading International S.A.? Do the E.O. 13850 blocking sanctions on Rosneft Trading S.A. and TNK Trading International S.A. apply to their corporate parent and their affiliates?

… which Rosneft Trading S.A. or TNK Trading International S.A. owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. eastern daylight time, May 20, 2020. After the … which Rosneft Trading, S.A. or TNK Trading International S.A. owns, directly or… Read more

818. Is there a wind-down period for transactions involving Rosneft Trading S.A. or TNK Trading International S.A.?

… which Rosneft Trading S.A. or TNK Trading International S.A., owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. eastern daylight time, May 20, 2020 (a prior … which Rosneft Trading S.A. or TNK Trading International S.A. owns, directly or… Read more

652. Is it permissible for mutual funds and exchange traded funds (collectively, “funds”) that are U.S. persons to buy, sell, or otherwise engage in transactions related to debt, equity, or other holdings in an entity that appears on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity owned 50 percent or more, individually or in the aggregate, by an individual or entity on the SDN List?

… List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity owned 50 percent or more, individually or in the aggregate, by an individual or entity on the SDN List? … List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity… Read more

595. What does Venezuela-related General License 5V authorize?

… as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization … persons may engage in certain transactions regarding any equity interest in an entity owned… Read more

1233. Are all entities engaged in a transaction authorized by Venezuela General License (GL) 46 required to have contracts with the dispute resolution requirement included in paragraph (a)(1)?

… de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (PdVSA Entities). This requirement does not apply to indirect … de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a… Read more

653. I am the manager of a Synthetic Exchange Traded Fund (ETF), which tracks a basket of debt, equity or other holdings in order to provide a return approximating the returns on that basket, but which does not actually hold the underlying debt, equity, or other holdings contained in the basket. May I continue to offer such funds, and may U.S. persons trade in shares of these funds, if the underlying basket being tracked contains holdings in an entity or entities that appear on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), or of an entity owned 50 percent or more, individually or in the aggregate, by an individual or entity on the SDN List?

854. What does General License 38 authorize?

… and activities involving CEIEC, or any entity in which CEIEC owns, directly or indirectly, a 50 percent or greater interest (collectively, Blocked CEIEC Entities), through 12:01 a.m. eastern … and activities involving CEIEC, or any entity in which CEIEC owns, directly or… Read more

661. What does General License 9H authorize with respect to Petróleos de Venezuela, S.A. (PdVSA) debt and equity and what are the implications for U.S. and non-U.S. persons?

… to dealings in any debt of, or equity in, PdVSA, or any entity directly or indirectly owned 50 percent or more by PdVSA, that was issued prior to August 25, 2017 (together, "PdVSA … to dealings in any debt of, or equity in, PdVSA, or any entity directly or indirectly owned… Read more

1125. I am a creditor of the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or a PdVSA subsidiary. Do I need an OFAC license to negotiate the settlement of claims related to assets of the Government of Venezuela or PdVSA?

… Government of Venezuela, PdVSA, or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (a "PdVSA Subsidiary"). For the purposes of GL 42, the term “IV … Government of Venezuela, PdVSA, or any entity in which PdVSA owns, directly or… Read more

Frequently Asked Questions

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