Case No. VENEZUELA-2021-372906-1
[***]
Dear [***]:
This letter responds to your request of March 4, 2021 (the “Application”) to the Office of Foreign Assets Control (OFAC), seeking authorization for the movement of bonds issued by the Government Venezuela (GOV) from a bank account in Italy under your sole control to an account in a different bank in Italy also under your control.
On August 24, 2017, the President issued Executive Order 13808 “Imposing Additional Sanctions with Respect to the Situation in Venezuela” (“E.O. 13808”), which prohibits, among other things, engaging in transactions related to, providing financing for, or otherwise dealing in bonds issued by the GOV prior to August 25.2017. Furthermore, on August 5. 2019. the President issued Executive Order 13884. “Blocking Property of the Government of Venezuela” (“E.O. 13884”), which blocks all property and interests in property...
1) Venezuela GL 3H authorized “all transactions related to, the provision of financing for, and other dealings in [covered] bonds…authorized, provided that any divestment or transfer of, or facilitation of divestment or transfer of, any holdings in such bonds must be to a non-U.S. person.” The applicant, who is clearly a U.S. person given the lack of any other identified U.S. nexus (the relevant banks are in Italy) and reference to "transfer of interests to other U.S. persons," sought authorization for the “movement of bonds” on the GL 3H annex from “from a bank account in Italy under [Applicant’s] sole control to an account in a different bank in Italy also under [Applicant’s] control.” OFAC concludes that “[t]the current and destination accounts are under [Applicant’s] exclusive control and the proposed activity involves only a custodial change, but no...