Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.
Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).
Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category).
Please contact [email protected] or [email protected] with any questions on search results and efficiency.
Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.
As of this writing, a number of OFAC authorizations authorize transactions related to the restructuring of debt of the GoV, including PdVSA. These authorizations differ in scope and overlap to some extent.
• Venezuela GL 3 and Venezuela GL 9
Venezuela GL 3 authorizes “all transactions related to…and other dealings in” covered GoV bonds, and FAQ # 547 says that GL 3 covers “participating in negotiations regarding such bonds,” provided that there is no actual “creation or subsequent dealing in new debt of PdVSA or debt otherwise of the Government of Venezuela”. This makes clear enough that transaction of U.S. person debtholders (and transactions of U.S. person incident to transactions of non-U.S. person debtholders) are covered as it relates to restructuring negotiations, and the logic of FAQ...