On May 12, 2020, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) announced that U.S. persons no longer need OFAC authorization to engage in dealings with Nynas AB, provided such activities do not involve blocked persons or otherwise prohibited activities. Further, Nynas AB is no longer subject to U.S. blocking sanctions as the entity has restructured and is no longer majority-owned by a sanctioned party.

Below are the specific changes:

  • OFAC revoked General License (GL) 13E, “Authorizing Certain Activities Involving Nynas AB,” as it is no longer needed.
  • OFAC issued GL 3H (“Authorizing Transactions Related to, Provision of Financing for, and Other Dealings in Certain Bonds”), which replaces and supersedes GL 3G. The only change was to remove Nynas AB, which was previously excepted from the GL’s authorization. The GL continues to have restrictions on bonds issued by PDV Holding, Inc. and CITGO.
  • OFAC similarly issued GL 9G (“Authorizing Transactions Related to Dealings in Certain Securities”), replacing and superseding GL 9F, to remove the reference to Nynas AB, meaning that the authorization applies to Nynas AB-issued securities that otherwise meet the criteria set forth in the GL. The GL continues to have restrictions on securities issued by PDV Holding, Inc. and CITGO.
OFAC emphasizes that absent agency authorization, U.S. persons continue to be prohibited from engaging in activities with Petróleos de Venezuela, S.A. (PdVSA), or entities in which PdVSA owns, directly or indirectly, a 50 percent or greater interest.