Careers

Diversity, Equity & Inclusion

Experience

Innovation

Interactive Maps

Locations

About

Pages

Meet our team of innovators
Ask us how we do it

Professionals

Insights

Services

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.

Home | Thompson Hine LLP

Atlanta

Chicago

Cincinnati

Cleveland

Columbus

Dayton

Los Angeles

Minneapolis

New York

Silicon Valley

Washington, D.C.

Despite a tightening of economic sanctions on Venezuela under President Donald Trump, the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) occasionally issues General Licenses clarifying, authorizing or exempting certain U.S. activities involving the Venezuelan government &nbsp;or entities directly and indirectly affiliated with Petr&oacute;leos de Venezuela, S.A (PdVSA). &nbsp;Starting in January 2019, President Trump issued an Executive Order expanding the sanctions targeting PdVSA (see <a href="https://www.trumpandtrade.com/2019/01/new-sanctions-imposed-venezuela-include-pdvsa-eight-new-ofac-general-licenses-released/#more-2393">Trump and Trade Update of January 19, 2019</a>).&nbsp; One such license, General License 5, addressed the ability to enforce bondholder rights to any CITGO shares serving as collateral for the &ldquo;Petr&oacute;leos de Venezuela, S.A. 2020 8.5 percent bond.&rdquo; &nbsp;This general license removed certain restrictions contained in <a href="https://www.treasury.gov/resource-center/sanctions/Programs/Documents/venezuela_eo_13835.pdf">Executive Order 13835</a> (Section1(a)(iii)) as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.
On April 10, 2020, OFAC issued <a href="https://www.treasury.gov/resource-center/sanctions/Programs/Documents/venezuela_gl5c.pdf">General License 5C</a>&nbsp;that delayed the license until July 22, 2020. &nbsp;Until then, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.&nbsp; OFAC notes:&nbsp; &ldquo;To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply.&nbsp; OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.&rdquo;
&nbsp;

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

OFAC Issues Venezuela General License Authorizing Continued Transactions Related to PdVSA Bond