Case No. VENEZUELA-2018-351691-1

Date issued: Nov. 25 2019

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TURBOFAC Commentary (248 words)

Notes:

1) The applicant seeks authorization to process a coupon (interest) payment related to PdVSA a bond that “matured on April 12, 2017”. According to the guidance letter, the interest payment was initially “was sent in May 2017,” returned, and then sent again in “November of 2017, and it was held by Sanctions compliance.” OFAC determines that no authorization is required to make the payment.

OFAC determines that no authorization is required to process the interest payment. OFAC cites Venezuela General License 9F, which authorizes “that are ordinarily incident and necessary to dealings in any debt…of…PDVSA…issued prior to August 25, 2017.” That the GL authorizes interest payments otherwise prohibited by EO 13884 and EO 13850 (blocking prohibition) is consistent with OFAC’s guidance at FAQ # 661 (“engaging in transactions related to...