Subsection 1(a)(i) of E.O. 13808 prohibits U.S. persons from dealing in new debt with a maturity of greater than 90 days of PdVSA. For purposes of E.O. 13808, does the term “PdVSA” include all PdVSA subsidiaries?

Question

Accepted Answer

Yes. For purposes of [E.O. 13808](https://ofac.treasury.gov/media/5476/download?inline), the prohibition in Subsection 1(a)(i) would apply to PdVSA and extend to all PdVSA subsidiaries, unless authorized by OFAC. Note that General License 2 authorizes certain activities involving specified PdVSA subsidiaries.

Subsection 1(a)(i) of E.O. 13808 prohibits U.S. persons from dealing in new debt with a maturity of greater than 90 days of PdVSA. For purposes of E.O. 13808, does the term “PdVSA” include all PdVSA subsidiaries?

OFAC's answer

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