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OFFICE OF FOREIGN ASSETS CONTROL
Venezuela Sanctions Regulations 31 C.F.R. Part 591
GENERAL LICENSE NO. 36A
Authorizing Certain Activities Necessary to the Wind Down of Transactions Involving Rosneft Trading S.A. or TNK Trading International S.A.
(a) Except as provided in paragraph (b) of this general license, all transactions and activities prohibited by Executive Order (E.O.) 13850 of November 1, 2018, as amended by E.O. 13857 of January 25, 2019, and incorporated into the Venezuela Sanctions Regulations, 31 C.F.R. part 591 (the VSR), that are ordinarily incident and necessary to the wind down of transactions involving Rosneft Trading S.A. or TNK Trading International S.A., or any entity in which Rosneft Trading S.A. or TNK Trading International S.A. owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, May 20, 2020.
(b) This general license does not authorize:
(1) Any debit to an account of Rosneft Trading S.A. or TNK Trading International S.A., or any entity in which Rosneft Trading S.A. or TNK Trading International S.A. owns, directly or indirectly, a 50 percent or greater interest, on the books of a U.S. financial institution; or
(2) Any transactions or activities otherwise prohibited by the VSR, or any other part of 31 C.F.R. chapter V, or any transactions or activities with any blocked person other than the blocked persons identified in paragraph (a) of this general license.
(c) Effective March 12, 2020, General License No. 36, dated February 18, 2020, is replaced and superseded in its entirety by this General License No. 36A.
Andrea Gacki
Director
Office of Foreign Assets Control
Dated March 12, 2020
1) This is a standard wind-down general license, authorizing the processing of underlying transactions that may not involve U.S. persons (see e.g. FAQ 807), but not including authorizations for the "maintenance" of activities. See corresponding designation notice at https://home.treasury.gov/news/press-releases/sm909.
2) Refer to the Research System for documents dealing with the scope of the types of transactions that qualify for "wind down" GLs such as this. (All general licenses for the wind down of pre-existing business activities.)
3) Read in conjunction with FAQ # 817 and FAQ # 818, both of which were issued on the same day as this GL.
4) GL Amended on 12 March 2020 to add TNK Trading International S.A. to the license.