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OFFICE OF FOREIGN ASSETS CONTROL
Venezuela Sanctions Regulations
31 CFR part 591
GENERAL LICENSE NO. 58
Authorizing Certain Services to the Government of Venezuela in Connection with Potential Debt Restructuring
(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), that are ordinarily incident and necessary to the provision of legal, financial advisory, and consulting services to the Government of Venezuela, including Petróleos de Venezuela, S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), in connection with potential restructuring of debt of the Government of Venezuela, including debt of PdVSA and PdVSA Entities, are authorized.
Note 1 to paragraph (a). For purposes of this general license,...
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1) Read in conjunction with FAQ # 547, Venezuela GL 3 and Venezuela GL 9. Prior to the issuance of this GL, Venezuela GL 3 and Venezuela GL 9 have long authorized “participating in negotiations” concerning “restructuring outstanding Venezuelan and PDVSA debt” (but not a transaction that “involves the creation or subsequent dealing in new debt of PdVSA or debt otherwise of the Government of Venezuela” (that would implicate the “new debt” prohibition of EO 13808). As it relates to the range of pre-sanctions debts covered by Venezuela GL 3 and Venezuela GL 9, this GL does not appear to provide much in the way of additional authorizations, and is indeed even narrower than Venezuela GL 3 and Venezuela GL 9 given the lack of authorization to negotiate directly with PdVSA/GoV (where there is...