OFAC Venezuela General License 5Y — Authorising PdVSA Bond Transactions from September 17

OFAC issued Venezuela General License 5Y on August 3, 2026, authorising all transactions related to, financing for, and other dealings in the Petróleos de Venezuela S.A. 2020 8.5% Bond on or after September 17, 2026. The GL replaces and supersedes GL 5X (which had authorised the same transactions from August 4). For clients with Venezuela sovereign debt exposure, commodity trading operations, or energy sector investments dependent on PdVSA activity, the rolling general license structure reflects the continuing tactical use of targeted sanctions relief to maintain political leverage over Venezuelan government conduct without a comprehensive sanctions lift. For law firms advising on Venezuela-related transactions, the succession of general licenses — 5W to 5X to 5Y in rapid succession — creates a compliance tracking obligation: counsel must verify that the applicable GL is current at the time of any transaction and that the transaction falls within the authorised scope, because authorisations that have been superseded by a new GL are no longer operative.