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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On September 10, 2021, the U.S. Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) issued&nbsp;<a href="https://home.treasury.gov/system/files/126/venezuela_gl5h.pdf" target="_blank" rel="noopener">General License (GL) 5H</a>, &ldquo;Authorizing Certain Transactions Related to the Petr&oacute;leos de Venezuela, S.A. 2020 8.5 Percent Bond on or After January 21, 2022,&rdquo; which continues to delay U.S. persons&rsquo; ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petr&oacute;leos de Venezuela, S.A. (PdVSA) 2020 8.5% bond until on or after January 21, 2022. The previous deadline had been October 21, 2021. Effective September 10, 2021, this GL 5H replaces GL 5G. Additionally, OFAC modified <a href="https://home.treasury.gov/policy-issues/financial-sanctions/faqs/595" target="_blank" rel="noopener">frequently asked question #595</a>&nbsp;to address the scope of GL 5H.
With this new General License, U.S. persons remain prohibited until January 21, 2022 from engaging in any transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5% Bond, unless specifically authorized by OFAC. In the modified FAQ 595, OFAC notes a favorable licensing policy toward those seeking to apply for a specific license in an effort to reach an agreement on proposals to &ldquo;restructure or refinance payments due to the holders of the PdVSA 2020 8.5% bond.&rdquo; See Update of&nbsp;<a href="https://www.thompsonhinesmartrade.com/2021/07/ofac-issues-general-license-extending-delay-of-pdvsa-2020-8-5-bond-related-authorizations/">July 21, 2021&nbsp;</a>for prior OFAC activity on this issue.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

International Trade

OFAC Issues Latest General License Update Extending Delay of PdVSA 2020 8.5% Bond-Related Authorizations