On March 14, 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. More specifically, OFAC issued General License 7A extending the deadline established by General License 7 to conduct transactions and activities with respect to PDV Holding, Inc. (PDVH), CITGO Holding, Inc., and their subsidiaries. Originally, these transactions had to be conducted by 12:01 a.m., eastern daylight time, July 27, 2019. With General License 7A, OFAC’s authorization now has a 18 month deadline that is renewed automatically on the first day of each month.