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LICENSE No. VENEZUELA-EO13850-2021-373984-1
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, and 13884, and 31 C.F.R. Parts 501 and 591.)
To: Gramercy Funds Management LLC
[ ]
1330 Connecticut Avenue NW
Washington, DC 20036
Attn: [ ]
1. Based upon the request dated April 23, 2021, and subsequent related correspondence, on behalf of Gramercy Funds Management LLC ("Gramercy") and Schlumberger Venezuela SA, and information otherwise available to the Office of Foreign Assets Control, the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee comply with its terms and with all regulations, rulings, orders, and instructions...
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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. ...