LICENSE No. VENEZUELA-EO13850-2020-370943-1

Date issued: Dec. 31 2020

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TURBOFAC Commentary (932 words)

Notes:

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...