April 9, 2019
Introduction
On January 28, 2019 the U.S. designated Petroleos de Venezuela S.A. (“PdVSA”) to the U.S. Specially Designated Nationals List (“SDN List”). The immediate effect was that U.S. persons were generally prohibited from engaging in any transactions with PdVSA and all of PdVSA’s property and interest in property in the United States were blocked. These restrictions also applied to any entity 50% or more owned by PdVSA.
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