THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

NEWS

Banks responsible if they fail to stop Venezuela debt deal with US person

February, 2019

Institutions urged to ensure certain trades are not ‘consummated’.

OFAC has issued 11 FAQs in connection with its designation of Venezuelan oil company PdVSA. Inter alia, it notes that General License 9 requires that any divestment or transfer by US persons of debt of Petróleos de Venezuela, S.A. (‘PdVSA’) (or any entity in which PdVSA owns, directly or indirectly, a 50% or greater interest), that was issued prior to 25 August 2017, be to a non-US person: ‘General License 9 also authorizes U.S. persons to facilitate the transfer or divestment of such debt, so long as the divestment or transfer of any holdings in such debt by a U.S....

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