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Financial Services Law Insights and Observations

OFAC revises Venezuela-related General Licenses on sanctioned oil company, issues new FAQs

Financial Crimes OFAC Department of Treasury Sanctions Venezuela

Financial Crimes

On February 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) amended two General Licenses (GL) and issued two new FAQs regarding sanctions against Venezuela’s state-owned oil company pursuant to Executive Order 13850.

OFAC amended GL 3B to authorize transactions related to, provision of financing for, and other dealings in certain bonds. GL 9A, which supersedes GL 9, authorizes certain transactions related to securities issued prior to August 25, 2017 by the oil company and its subsidiaries. GL 9A and related FAQ 661 clarify that trades in the oil company’s securities placed prior to 4:00 pm EST on January 28, 2019, are generally authorized “to settle in the ordinary course, irrespective of whether the sale or transfer is to a non-U.S. person.”

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