LICENSE No. VENEZUELA-EO13850-2021-373984-1 [Application included]

Date issued: May. 02 2022

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TURBOFAC Commentary (406 words)

Notes:

1) Compare LICENSE No. VENEZUELA-EO13850-2020-370943-1 (similar but issued two years prior to the same investment fund).

2) Here, OFAC authorizes a U.S. person (Gramercy Funds Management LLC) to purchase certain debt of PdVSA subsidiaries. Note that the SL is cast as a “TEAR” (“to the extent that authorization is required”) in light of the arguments in the application that, at least for the vast majority of receivables purchased, no license should be required.

3) At the time the license was issued Venezuela General License 9G authorized U.S. persons divest pre-sanctions debt of PdVSA (but not “new debt”). This would have allowed Schlumberger to engage in sales of most of the receivables, but not to the U.S. person Gramercy, because there was a carveout for U.S. person investment in such debt. ...