Introduction
On May 21, 2018, President Trump issued an Executive Order titled “Prohibiting Certain Additional Transactions with Respect to Venezuela” (hereinafter, the “May 21 Executive Order”). The May 21 Executive Order imposes new restrictions on transactions involving debt owed to the Government of Venezuela and its related entities, including accounts receivable, and certain transactions involving the Government of Venezuela with respect to equity interests in any entity in which the Government of Venezuela has a 50 percent or greater ownership interest.
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