On March 8, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) further amended the general licenses governing secondary trading of pre-sanctions Government of Venezuela (GoV) debt and Petróleos de Venezuela, S.A. (PdVSA) debt and equity by issuing new General Licenses (GL) 3D and 9C. In both, OFAC extended the authorization for all transactions and activities ordinarily incident and necessary to winding down financial contracts or other agreements entered into before January 28, 2019 (for transactions involving PdVSA debt and equity) or February 1, 2019 (for transactions involving certain GoV debt listed in GL 3D) to May 10, 2019.
OFAC has stated that these authorizations permit settling trades entered into prior to the relevant restrictions even where the related sale or transfer is to a U.S. person. OFAC also revised previously issued FAQ guidance to reflect the extended expiration dates.