Department of The Treasury: WASHINGTON, D.C. 20220
Department of The Treasury: WASHINGTON, D.C. 20220
(a) Except as provided in paragraph (b) of this general license, all transactions and
activities prohibited by Executive Order (E.O.) 13850 of November 1, 2018, as amended by
E.O. 13857 of January 25, 2019, and incorporated into the Venezuela Sanctions Regulations,
31 C.F.R. part 591 (the VSR), that are ordinarily incident and necessary to the wind down of
transactions involving Rosneft Trading S.A. or TNK Trading International S.A., or any entity in
which Rosneft Trading S.A. or TNK Trading International S.A. owns, directly or indirectly, a 50
percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, May 20,
2020.
(1) Any debit to an account of Rosneft Trading S.A. or TNK Trading International S.A.,
or any entity in which Rosneft Trading S.A. or TNK Trading International S.A. owns, directly or
indirectly, a 50 percent or greater interest, on the books of a U.S. financial institution; or
(2) Any transactions or activities otherwise prohibited by the VSR, or any other part of
31 C.F.R. chapter V, or any transactions or activities with any blocked person other than the
blocked persons identified in paragraph (a) of this general license.
(c) Effective March 12, 2020, General License No. 36, dated February 18, 2020, is
replaced and superseded in its entirety by this General License No. 36A.
Andrea Gacki
Director
Office of Foreign Assets Control