United States Initiates Issuance Of Venezuela Related General License And Amended Frequently Asked Question.

Washington DC; February 2026: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing:

• Venezuela-related General License 5U, Authorising Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 20, 2026.

• Additionally, OFAC is also issuing amended Venezuela-related Frequently Asked Question (FAQ 595).

Venezuela-related General License 5U –

(a) Except as provided in paragraph (b) of this general license, on or after March 20, 2026, all transactions related to, the provision of financing for, and other dealings in the Petróleos de Venezuela, S.A. 2020 8.5% (Percent) Bond that would be prohibited by subsection l(a)(iii) of Executive Order (E.O.) 13835 of May 21, 2018, as amended by E.O. 13857 of January 25, 2019, and incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), are authorised.

(b) This general license does not authorise any transactions or activities otherwise prohibited by the VSR, or any other part of 31 CFR chapter V.

(c) Effective February 2, 2026, General License No. 5T, dated December 19, 2025, is replaced and superseded in its entirety by this General License No. 5U.

What does Venezuela-related General License 5U authorise 595? –

President Donald Trump had issued Executive Order (E.O.) 13835 on May 21, 2018 during his erstwhile Presidency. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50% or more by the GOV.

One effect of subsection 1(a)(iii) is to require authorisation before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50% or more by the GOV. Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5% (Percent) bond. OFAC issued General License (GL) 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.

General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorisation in the general license. Since that date, OFAC has extended the delay in effectiveness multiple times.

Most recently, OFAC issued General License 5U today – on February 2, 2026, which further delays the effectiveness of the authorisation in GL 5 until March 20, 2026. Between October 24, 2019 and March 20, 2026 (the date the authorisation in General License 5U becomes effective), there is no authorisation in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5% (Percent) bond. As a result, during such 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.

To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.

Executive Order (E.O.) 13835 dated May 21, 2018 –

Prohibiting Certain Additional Transactions With Respect to Venezuela

By the authority vested in me as President by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.), and section 301 of title 3, United States Code, I, DONALD J. TRUMP, President of the United States of America, in order to take additional steps with respect to the national emergency declared in Executive Order 13692 of March 8, 2015, and relied upon for additional steps taken in Executive Order 13808 of August 24, 2017 and Executive Order 13827 of March 19, 2018, particularly in light of the recent activities of the Maduro regime, including endemic economic mismanagement and public corruption at the expense of the Venezuelan people and their prosperity, and ongoing repression of the political opposition; attempts to undermine democratic order by holding snap elections that are neither free nor fair; and the regime’s responsibility for the deepening humanitarian and public health crisis in Venezuela, hereby order as follows:

Section 1. (a) All transactions related to, provision of financing for, and other dealings in the following by a United States person or within the United States are prohibited:

• the purchase of any debt owed to the Government of Venezuela, including accounts receivable;

• any debt owed to the Government of Venezuela that is pledged as collateral after the effective date of this order, including accounts receivable; and

• the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela of any equity interest in any entity in which the Government of Venezuela has a 50% or greater ownership interest.

Section 1. (b) The prohibitions in subsection (a) of this section apply except to the extent provided by statutes, or in regulations, orders, directives, or licenses that may be issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted before the effective date of this order.

Section 2. (a) Any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions set forth in this order is prohibited.

Section 2. (b) Any conspiracy formed to violate any of the prohibitions set forth in this order is prohibited.

Section 3. For the purposes of this order:

(a) The term ‘‘person’’ means an individual or entity;

(b) The term ‘‘entity’’ means a partnership, association, trust, joint venture, corporation, group, subgroup, or other organisation;

(c) the term ‘‘United States person’’ means any United States citizen, permanent resident alien, entity organised under the laws of the United States or any jurisdiction within the United States (including foreign branches of such entities), or any person within the United States; and

(d) the term ‘‘Government of Venezuela’’ means the Government of Venezuela, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A. (PdVSA) and any person owned or controlled by, or acting for or on behalf of,

the Government of Venezuela.

Section 4. The Secretary of the Treasury, in consultation with the Secretary of State, is hereby authorised to take such actions, including promulgating rules and regulations, and to employ all powers granted to the President by IEEPA as may be necessary to implement this order. The Secretary of the Treasury may, consistent with applicable law, re-delegate any of these functions to other officers and executive departments and agencies of the United States Government. All agencies of the United States Government shall take all appropriate measures within their authority to carry out the provisions of this order.

Section 5. This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.

Section 6. This order is effective at 12:30 p.m. eastern daylight time on May 21, 2018.

Team Maverick.