PRINT
LICENSE No. VENEZUELA-2025-1354711-1
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: Siemens Energy, Inc.
c/o Reed Smith LLP
225 Fifth Ave
Pittsburgh, PA 15222
Attn: Stephan Johansen
1. Based upon the request dated March 13, 2025, on behalf of Siemens Energy, Inc., to the Office of Foreign Assets Control (“OFAC”), and information otherwise available to OFAC (the “Application”), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and instructions issued under any of the authorities cited...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) This license and associated application are notable for a number of reasons. First, from a licensing policy standpoint, it illustrates an apparently favorable licensing policy—likely still in place given the recency of the issuance of the license—with respect to the sale of judgments against the Venezuelan government by U.S. judgment holders to financial institution investors.
2) From a technical standpoint, the license, which is not issued as a TEAR (“to the extent authorization is required”) license, is notable insofar as it serves as a rejection of the applicants arguments that (i) blocked persons do not have an interest in judgments against them, and (ii) in any event sale of the judgment is covered by Venezuela Venezuela General License 9 and not prohibited by the “new debt” prohibition of