The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its revocation of general license 13E and issuance of general licenses 3H (“Authorizing Transactions Related to Dealings in Certain Bonds”) and 9G (“Authorizing Transactions Related to Dealings in Certain Securities”) to remove references to Nynas AB. Nynas is no longer being blocked pursuant to the Venezuela Sanctions Regulations, 31 C.F.R. Part 591 (VSR). These updates are also reflected in two Frequently Asked Questions about these general licenses.

In a previous Trump and Trade post, we discussed OFAC’s temporary extension of general license 13E to provide additional time for Nynas to complete its proposed corporate restructuring, which would result in, according to OFAC, “significant changes to Nynas’s ownership and control.” OFAC’s announcement confirms that the restructuring of Nynas is now complete, and consequently Nynas is no longer blocked pursuant to the VSR.

The restructuring has removed control by blocked persons of Nynas and has reduced the interest of blocked persons in Nynas below 50%. Accordingly, U.S. persons are no longer prohibited from engaging in transactions or activities with Nynas, and do not require authorization from OFAC to do so. Notably, absent authorization from OFAC, all U.S. persons continue to be prohibited from engaging in any dealings with Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50% or greater interest.

General licenses 3H and 9G replaced general licenses 3G and 9F, respectively. The only changes made to these licenses were the removal of references to Nynas.