Venezuela-related sanctions by the United States Department of the Treasury
Clearstream Banking1 refers to the publications made by the United States Department of the Treasury on 28 January 2019 with regards to Venezuela.
Clearstream Banking reminds customers of the requirement to comply, and ensure compliance by any of the customer’s underlying clients, with any applicable law or regulation.
Customers are additionally requested to note the following operational requirements:
Instructions to receive or deliver securities covered by General License 9
When instructing the receipt of any of securities covered by General License 9, customers must add the following new representation into the narrative field of their instruction (for example, field 70E of the MT54x instruction):
“We represent: this instruction is covered by OFAC General License 9; is necessary to transfer or divest the securities to a non-U.S. person; no SDN is involved; the ultimate recipient of the securities is neither a U.S. person nor an SDN or SDN equivalent.”
For domestic market settlement, the customer delivering securities to the domestic market must either provide the same representation, or alternatively, represent that the instruction relates to an on-exchange transaction.
Note: If for some reason it is not possible to add the representation to the narrative field of the instruction, we require a separate authorised communication which must provide the Transaction Reference(s) to allow reconciliation of the representation back to each instruction.
For further information, customers may contact Clearstream Banking Client Services or their Relationship Officer.
1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking AG customers using Creation Accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.