Venezuela-related General License 5Y

What's on the official record

On August 3, 2026, OFAC issued Venezuela-related General License 5Y, "Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After September 17, 2026." FAQ 595, updated the same day, states that subsection 1(a)(iii) of E.O. 13835 (May 21, 2018) prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela of any equity interest in an entity owned 50 percent or more by the Government of Venezuela.

General License 5, issued July 19, 2018, removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral. General License 5A replaced and superseded General License 5 on October 24, 2019 with a delay in the effectiveness of the authorization. OFAC has extended that delay multiple times; General License 5Y further delays the effectiveness of the authorization in General License 5 until September 17, 2026. Between October 24, 2019 and September 17, 2026, no authorization is in effect licensing against subsection 1(a)(iii) of E.O. 13835 for holders of the PdVSA 2020 8.5 percent bond. During that period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited unless specifically authorized by OFAC.

Assessment

For a sanctions committee: General License 5Y becomes effective on September 17, 2026. Until then, the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond is prohibited absent a specific authorization. To the extent an agreement on restructuring or refinancing payments due to holders of the PdVSA 2020 8.5 percent bond is reached, additional licensing requirements may apply; OFAC encourages a specific license application and states a favorable licensing policy toward such an agreement.

For a Country GM/CFO: the CITGO collateral clock does not move the operating book before September 17, 2026. Transactions related to the sale or transfer of CITGO shares tied to the PdVSA 2020 8.5 percent bond remain prohibited while no authorization is in effect, so September 17, 2026 is the date on which the book's exposure changes unless OFAC acts first.

For a vendor/platform: calendar September 17, 2026 as the date the authorization in General License 5Y becomes effective. A rule that treats the July 19, 2018 General License 5 issuance date as live authorization is the wrong clock; the live date is the General License 5Y effectiveness date.

What would change this call

The live 5Y clock	Hit if	Miss if
Does GL 5Y become effective on 17 Sep 2026, or does OFAC issue a further delay before that date?	GL 5Y becomes effective on 17 Sep 2026	OFAC issues a further delay before 17 Sep 2026

What to check next

Open question	What it takes	Where that comes from
Whether OFAC issues a further delay before 17 Sep 2026	A new Venezuela-related general license or amended FAQ dated before 17 Sep 2026	OFAC Recent Actions index; FAQ 595
Whether GL 5Y becomes effective on 17 Sep 2026	The authorization in General License 5 taking effect with no superseding Venezuela-related action	General License 5Y (media/936651); FAQ 595
Whether parties pursue a specific license for a restructuring or refinancing agreement	A specific license application and OFAC's favorable licensing policy	FAQ 595

Confidence

FAQ 595 and the August 3, 2026 action page were retrieved live this run; both name General License 5Y and the September 17, 2026 effectiveness date. The Recent Actions index, retrieved August 18, 2026, shows no Venezuela-related action dated after August 3, 2026. The August 18, 2026 action-day request returned HTTP 403 (auth_error), so no page for that date was retrievable.

Sources

[1] OFAC, FAQ 595 (updated 3 Aug 2026). https://ofac.treasury.gov/faqs/595

[2] OFAC, Issuance of Amended Venezuela-related General License and Frequently Asked Question (3 Aug 2026). https://ofac.treasury.gov/recent-actions/20260803

[3] OFAC, Recent Actions index (retrieved 18 Aug 2026). https://ofac.treasury.gov/recent-actions

[4] OFAC, Venezuela-related General License 5Y, "Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After September 17, 2026" (PDF). https://ofac.treasury.gov/media/936651/download?inline