I am a party seeking to enforce bondholder rights to the shares of CITGO Holding serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond, pending the outcome of ongoing litigation. How can I preserve or enforce my bondholder rights consistent with the Venezuela Sanctions Regulations, [31 CFR part 591](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-591/subpart-D/section-591.407) (VSR)?

Question

I am a party seeking to enforce bondholder rights to the shares of CITGO Holding serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond, pending the outcome of ongoing litigation.  How can I preserve or enforce my bondholder rights consistent with the Venezuela Sanctions Regulations, [31 CFR part 591](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-591/subpart-D/section-591.407) (VSR)?

Accepted Answer

OFAC will not take enforcement action against any person for taking steps to preserve the ability to enforce bondholder rights to the CITGO shares serving as collateral for the PdVSA 2020 8.5 percent bond (see also OFAC Frequently Asked Question (FAQ) [1123](https://ofac.treasury.gov/faqs/1123); [General License 42](https://ofac.treasury.gov/media/931696/download?inline) and OFAC FAQ [1125](https://ofac.treasury.gov/faqs/1125)).  This non-enforcement policy governs OFAC sanctions only and does not relieve persons of obligations to comply with any other applicable regulatory requirements, reviews, or approvals that may be necessary to finalize any sale.  As noted in FAQ [1125](https://ofac.treasury.gov/faqs/1125), parties that have negotiated a settlement agreement pursuant to [General License 42](https://ofac.treasury.gov/media/931696/download?inline) will still need to seek a specific license for entry into that agreement.

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