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LICENSE No. VENEZUELA-EO13850-2020-370943-1
VENEZUELA SANCTIONS REGULATIONS
LICENSE
Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, Pub. L. 113-278, Executive Orders 13692, 13808, 13827, 13835, 13850, 13857, 13884, and 31 C.F.R. Parts 501 and 591.
To: Gramercy Funds Management, LLC
c/o Steptoe & Johnson LLP
1330 Connecticut Avenue, NW
Washington, DC 20036
Attn: Brian J. Egan
1. Based upon the information received on December 5, 2020 and December 18, 2020 from Gramercy Funds Management, LLC, to the Office of Foreign Assets Control (OFAC) and information otherwise available to OFAC (collectively, the “Application”), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations,...
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1) As of 12-18-23, this is the only specific license in the Research System authorizing a U.S. person investment manager to purchase debt of blocked person (i.e. PdVSA/PDVSA Petróleo S.A.). Here, Gramercy Funds Management was a U.S. person investment manager, Servicios Halliburton de Venezuela, S.A. was a Venezuelan subsidiary of the U.S. person Halliburton, and "Gramercy’s investment vehicle" (referenced in section I(a) of the specific license) was a Cayman entity (see p. 3 of the PDF file, noting that "Girard Street Investment Holdings LLC" is the Assignee of the debt). It is notable, given that the general license allowing for dealings in PdVSA debt did not authorize the purchase of such debt, that OFAC was willing to grant the SL.
2) Relevance of GL 9G; Implicit Interpretations Thereof
(i) At the time...