Venezuela — the license clock that still has not opened
OFAC · State · 5 sources
What's on the official record
3 August — GL 5Y, another delay. OFAC replaced GL 5X (18 June 2026) with General License 5Y. The license authorizes, on or after 17 September 2026, transactions related to the Petróleos de Venezuela, S.A. 2020 8.5 percent bond that would otherwise be prohibited by subsection 1(a)(iii) of E.O. 13835. Until that date, FAQ 595 states there is no authorization in effect for those bondholder transactions. Sale or transfer of CITGO shares in connection with that bond remains prohibited unless OFAC specifically authorizes it.
3 August — FAQ 595 restated. OFAC traces the series: GL 5 (19 July 2018) removed E.O. 13835 as an obstacle to holders of that bond reaching their collateral; GL 5A (24 October 2019) introduced a delay; OFAC has extended that delay many times. 5Y is the current extension. If parties reach a restructuring or refinance of payments due on the bond, additional licensing may apply. OFAC says it would encourage a specific-license application and would have a favorable licensing policy toward such an agreement.
24 July — oil-revenue deposits. FAQ 1239 (updated that day) tells depositors how to reach the Foreign Government Deposit Funds account referenced in E.O. 14373 and in certain Venezuela general licenses: email DepositorInquiries@state.gov with named contract, invoice, license, and party details before sending funds. Deposits that skip that inbox may be rejected. That path does not move on the GL 5 calendar.
27 June — travel, Level 3. State keeps Venezuela at Level 3: Reconsider Travel, citing crime, kidnapping, terrorism, health infrastructure, and natural disaster. A 24 June earthquake is in the advisory. The U.S. Embassy in Caracas is on emergency American-citizen services only; visa services remain through Bogotá. Several interior and border areas are Level 4. Level is not a sanctions determination.
Assessment
For a sanctions committee, the bond/collateral clock has been a delay series since October 2019. 5Y continues that series through 17 September. It is a dated authorization that is not yet in effect. The oil-revenue clock is an operational deposit channel under E.O. 14373. FAQ 1239 sets a filing path. It leaves untouched who may lift or sell crude.
For a country GM/CFO, GL 5Y does not cover oil lift, service, or a local JV. The live license class for that activity is still the question.
For a vendor/platform, calendar 17 September as the 5Y effectiveness date; treating August silence on the SDN list as a quiet corridor is the wrong class.
What would change this call
| ID | Claim | Resolve by | Hit if | Miss if |
|---|---|---|---|---|
| F1 | OFAC issues another GL 5 successor (5Z or later) that pushes effectiveness past 17 September 2026. | 17 Sep 2026 | New GL posted on OFAC recent-actions before that date, delay still in force | 5Y becomes effective with no successor |
| F2 | If no successor posts, 5Y takes effect and the 2020 8.5 percent bond transactions described in the license are authorized against E.O. 13835 1(a)(iii) only. | 18 Sep 2026 | License text still 5Y; no new delay | Successor delay, or a specific license that replaces the general path |
| F3 | A specific license for a PdVSA 2020 bond restructuring or refinance is published or confirmed in an OFAC notice. | 90 days from 17 August 2026 | Named OFAC action | No such notice |
| F4 | State changes the Venezuela travel level, or the embassy restores more than emergency ACS. | Next advisory / embassy update | New level or service notice | Level 3 and emergency ACS unchanged |
Base case (stated so it can be wrong): F1 hits. The series since 2019 is delay. That is a reading of the official pattern, not a prediction of policy intent.
What to check next
| Open question | What it takes | Where that comes from |
|---|---|---|
| On-ground security, power, and site access after the June earthquake | Field report, local security | A field team or local security provider |
| Beneficial ownership of a Venezuela-adjacent intermediary | Corporate records, possibly field work | An investigations or corporate-integrity firm |
| A committee-ready opinion on a named counterparty or bond position | Known institutional file | A known institutional firm |
| Is a discrete dated policy event hedgeable (5Y effectiveness, license drop, corridor close)? | Event definition + notional | A priced-event specialist, privately |
Confidence
High on the official-page reading: what OFAC published on 3 August and 24 July, and the standing Level 3 advisory text. Medium on F1 — the delay series is long, and a series can end.
Sources
[1] OFAC, Issuance of Amended Venezuela-related General License and Frequently Asked Question, 3 Aug 2026. https://ofac.treasury.gov/recent-actions/20260803
[2] OFAC, General License No. 5Y, 3 Aug 2026. https://ofac.treasury.gov/media/936651/download?inline
[3] OFAC, FAQ 595 (updated 3 Aug 2026). https://ofac.treasury.gov/faqs/595
[4] OFAC, FAQ 1239 (updated 24 Jul 2026). https://ofac.treasury.gov/faqs/1239
[5] U.S. Department of State, Venezuela Travel Advisory (Level 3: Reconsider Travel), issued 27 Jun 2026. https://travel.state.gov/content/travel/en/traveladvisories/traveladvisories/venezuela-travel-advisory.html