On March 8, 2019, the Office of Foreign Assets Control (“OFAC”) issued new regulations regarding the January 28, 2019 designation of Petróleos de Venezuela, S.A. (“PDVSA”) and any entity in which PDVSA has, directly or indirectly, 50% or greater ownership interest such as Alba de Nicaragua S.A. (“ALBANISA”). More specifically, OFAC issued General Licenses 3D and 9C extending the deadline established by General Licenses 3C and 9B to conduct all transactions and activities that are ordinarily incident and necessary to the wind down of financial contracts or other agreements that were entered into (i) prior to 4:00 p.m. eastern standard time on February 1, 2019, involving, or linked to the bonds that are detailed in General License 3D; (ii) prior to 4:00 p.m. eastern standard time on January 28, 2019, involving, or linked to, PDVSA securities.Originally, the transactions described above had to be conducted by 12:01 a.m., eastern daylight time, March 11, 2019. With General Licenses 3D and 9C, the deadline was extended through 12:01 a.m. eastern daylight time, May 10, 2019.
