Green Light, Red Tape: Barriers to Venezuela’s Debt Restructuring

By Katherine Shen, Sovereign Debt Forum Fellow, Head of Research #PublicDebtIsPublic | May 15, 2026

On May 5, 2026, the U.S. Treasury issued General License 58, which allows Venezuela to hire advisors to restructure its debts and those of its state agencies and instrumentalities, including the oil company, Petróleos de Venezuela (PDVSA). The move was modest in scope—it stops far short of authorizing a debt settlement or payment transfers—but the signal was unmistakable. On May 13, Venezuela’s interim government announced it had formally launched the restructuring process.[1] For the first time since 2017, one of the world’s largest unresolved sovereign defaults[2] may be headed for resolution with a green light from the U.S. government.

Positive signals notwithstanding, serious roadblocks to restructuring remain. Venezuela owes approximately US$150-200 billion to creditors around the world: this includes roughly US$92 billion in defaulted sovereign, PDVSA, and electrical utility bonds,[3] over US$20 billion in arbitral awards,[4] bilateral loans whose full extent remains undisclosed, and interest on the above liabilities that has been compounding for nearly a decade. Although Venezuela is a resource-rich middle-income country, international sanctions cut off its access to global capital markets years ago and pushed its borrowing toward risky and opaque structures, including resource-backed loans more typical of low-income countries. Credible restructuring negotiations will require knowing, with precision, who holds what claims, on what legal terms, and in what priority. On all three counts, the answers remain elusive.

The Legibility Problem

The sheer variety of debt instruments issued by Venezuela and its entities is extraordinary. There are sovereign bonds governed by New York law, PDVSA bonds secured by its subsidiary’s stock, bilateral loan agreements with China and Russia structured as prepayment for oil deliveries, arbitral awards won by expropriated multinationals at ICSID, the ICC, and the PCA, plus promissory notes, credit agreements, and judgments scattered across courts in Delaware, New York, Washington D.C., England, Portugal, the Netherlands, and more. Each instrument carries its own covenants and conditions, express or implied priority, governing law, and enforcement mechanism.

The #PublicDebtIsPublic research team has spent the past several months mapping this landscape, collecting and cross-referencing primary source documents for money claims against Venezuela going back to 1990. The exercise has been illuminating, not only for what documents we found, but for how difficult it has been to find them.

All the documents we have collected are, in a technical sense, public—we do not publish paywalled or private information. However, there is a significant gap between a document that is theoretically available and one that is practically accessible and intelligible. Information about claims and claimants on Venezuela is extremely difficult to piece together in a coherent and understandable way. Documents are published across different government agencies, regulatory and investigative media websites, and stock exchanges in multiple jurisdictions. Certain key contracts surface only when lawsuits force them into court filings. Arbitral awards—of which there are many, and in significant amounts—are routinely omitted from sovereign debt inventories. Bilateral loan agreements, including those with China and Russia, require multilingual detective work to surface.

Venezuela is not an outlier. It is a case study in near-universal failure: partial, inconsistent, convoluted, and fragmented sovereign debt disclosure. Opacity is the unstated norm.

In our experience building the #PublicDebtIsPublic platform, publication practices vary widely. Bond terms may be published on stock exchange, regulator, and borrower websites. Non-bonded debt disclosure is often borrower-driven and heavily influenced by borrowers’ domestic legal requirements.[5] Parliaments and other accountability institutions play important roles. Venezuela has fallen short of this transparency standard (among others) for decades.[6]

Bilateral official creditors, commercial banks, and state-owned entities rarely publish debt contracts, at least not voluntarily.[7] Older multilateral development banks with broad-based global membership are the notable exception: the World Bank, for instance, routinely publishes its general terms and conditions and specific loan terms. Many other multilateral, regional, and plurilateral institutions do not. For instance, CAF – the Development Bank of Latin America and the Caribbean (formerly the Andean Development Corporation)[8] has been an important lender to Venezuela, but does not publish its general conditions or specific contracts, forcing researchers to reconstruct its lending template from several dozen contracts published by other borrowing governments. In a fragmented information system where transparency is the exception rather than the rule, restructuring negotiations pose a challenge even for the most well-resourced and well-intentioned participants, and a far bigger challenge for public oversight.

The CITGO Question

No single feature of Venezuela’s debt stock illustrates its complexity more vividly than CITGO Petroleum, a Houston-based refiner and PDVSA subsidiary that sits at the center of a cascading series of enforcement actions in the U.S. courts.

Figure 1: PDVSA-CITGO Chain of Corporate Ownership and 2020 Notes Collateral Arrangement

See: U.S. District Court, SDNY, October 16, 2020, 495 F. Supp. 3d 257, pp.3 to 5.

CITGO is simultaneously a major U.S. energy asset—the fifth largest oil refiner in the United States—and the primary vehicle for creditor enforcement against Venezuela in U.S. courts. A key legal development came in 2018, when Crystallex, a Canadian mining company holding a US$1.2 billion ICSID award against Venezuela for the expropriation of a gold deposit, obtained a landmark ruling that brought PDVSA’s U.S. assets within reach of the government’s creditors. By ruling that the state-owned oil company is Venezuela’s alter ego,[9] the court cleared the way for creditors holding judgments against Venezuela to seize PDVSA’s shares in PDV Holding, CITGO’s parent company. The broader implication of the ruling is that a state-owned enterprise’s assets can become the vehicle for sovereign debt enforcement, and a state-owned enterprise’s debt becomes a sovereign’s debt. A queue of creditors quickly formed as a result: OI European Group, Tidewater, Valores Mundiales, and others together pursued over $20 billion in claims against CITGO, whose assets are estimated to be worth US$13 billion.[10]

Figure 2: Waterfall of Judgment Creditors Enforcing Against PDV Holding shares

Priority Order and Estimated Claims

See Crystallex International Corporation v. Bolivarian Republic of Venezuela, 1:17-mc-00151, (D. Del. Nov 25, 2025) ECF No. 2553, p.31.

Collateralization compounds the complexity. Before the U.S. federal court issued its alter egodecision, PDVSA had pledged 50.1% of CITGO Holding as security in a debt restructuring. This meant that unsecured judgment creditors of Venezuela were lining up to seize the very same shares that had been pledged to a group of PDVSA’s secured creditors: the holders of its 2020 Notes. Litigation over the validity of that pledge turned on a threshold choice-of-law question: whether New York or Venezuelan law governed the CITGO security arrangement and its consequences. The highest court in the State of New York held in February 2024 that Venezuelan law applied;[11] then on remand, the U.S. federal court found the bonds valid under Venezuelan law, and issued a US$2 billion judgment in favor of the secured PDVSA bondholders, which is now pending appeal before the Second Circuit.[12] Nonetheless, the judgment in favor of the PDVSA bondholders seems to set them on a collision course with Venezuela’s judgment creditors and others trying to seize the same CITGO shares.[13]

In November 2025, the Delaware district court tasked with mediating that contest approved a roughly US$8 billion bid for PDV Holding by Amber Energy, an affiliate of Elliott Investment Management, in a forced sale to satisfy creditors.[14] The sale remains on hold pending U.S. Treasury approval and the Delaware court’s decision is also on appeal before the Third Circuit.[15]

The problem illustrated by the litigation around CITGO is severe and straightforward: a single creditor’s attempt to enforce its claim triggers a scramble among claimants for finite and over-encumbered assets. There is no bankruptcy court to short-circuit the scramble.

Bilateral Creditors: China and Russia

When sanctions cut Venezuela off from international bond markets, official bilateral and state-owned bank loans became an important lifeline, with their customary mix of policy and economic objectives. China and Russia reportedly have some of the biggest claims in a potential restructuring of Venezuela’s sovereign debt, even though the amount and terms of their loans remain opaque. For instance, the China Development Bank (CDB) has extended a three-tranche loan totaling US$18 billion to Venezuela,[16] structured so that oil sale proceeds flow directly into collection accounts controlled by the lender.[17] The arrangement includes the Sino-Venezuela Joint Financing Fund, which operates through a layered architecture of commercial agreements sitting beneath the intergovernmental framework. To capitalize and grow this fund, China and Venezuela entered into the following agreements:

A Framework Agreement among the China Development Bank (CDB), China National United Oil Corporation (CHINAOIL), Banco de Desarrollo Económico y Social de Venezuela (BANDES), PDVSA Petróleo S.A (PDVSA Petróleo), Fondo de Desarrollo Nacional S.A. (FONDEN), and Venezuela’s Ministries of Finance and Energy to increase the Sino-Venezuela Joint Fund through a US$2 billion contribution by FONDEN and a term loan facility of up to US$4 billion loan from CDB to BANDES;[18]
A Four Party Agreement among BANDES, PDVSA Petróleo, CHINAOIL, and CDB, coordinating their interlocking obligations. It requires CHINAOIL to pay all sale proceeds generated under the Petroleum Sales and Purchase Contract into a collection account held at CDB, not to PDVSA Petróleo. CDB then applies the amount in that account against BANDES’ repayment obligations under the facility agreement relating to the US$4 billion loan. However, BANDES’ repayment obligation to CDB is absolute and independent of the oil proceeds.
A Petroleum Sales and Purchase Contract under which PDVSA Petróleo commits to delivering 230,000 barrels of fuel and/or crude oil per day to CHINAOIL, with all proceeds irrevocably directed to CDB’s collection account; and
An Account Management Agreement governing the operation of CDB’s collection account and the strict withdrawal restrictions that protect CDB’s repayment stream.[19]

If the structure itself were not complex enough, it turns out that the agreements at its foundation are governed by the laws of at least three jurisdictions, with at least two different dispute resolution mechanisms (Fig. 3). The Framework Agreement, Four Party Agreement, and Petroleum Sales and Purchase Contract are subject to UNCITRAL arbitration administered by the Singapore International Arbitration Centre (SIAC). The Framework Agreement and Four Party Agreement are governed by English law and the Petroleum Sales and Purchase Contract is governed by Venezuelan law. The Account Management Agreement is governed by Chinese law with disputes resolved by the China International Economic and Trade Arbitration Commission (CIETAC) in Beijing.

Figure 3: Governing Law and Dispute Resolution in Venezuela’s Oil-backed CDB Loans

Such jurisdictional fragmentation compounds the restructuring challenge: unwinding the oil-for-loan repayment mechanism would require renegotiating not just the sovereign intergovernmental framework but a web of independent commercial contracts binding Venezuela and Venezuelan entities, as well as their Chinese counterparties under different legal regimes, before different arbitral tribunals.

Russia has similarly used complex structures in its bilateral financing for Venezuela. For instance, a US$4 billion state credit, extended at 7.4% beginning in late 2011, apparently implicated a mix of arms sales and oil investments. The loan document (coming soon to the #PublicDebtIsPublic platform) references additional cooperation agreements and jointly owned financial institutions based in Moscow. It does not specify governing law or dispute resolution procedures, apart from amicable consultation.

These and other bilateral loans matter enormously for restructuring design and countries’ aspirations for debt sustainability. Bringing creditors with access to the borrowing country’s foreign currency revenues into the restructuring perimeter is very hard, all else equal. Convincing Russia and China to join a comprehensive collective restructuring process so visibly driven by Washington, may be harder still. Opacity surrounding bilateral loans destroys trust, already in short supply on both sides of the lending relationship, and stands in the way of inter-creditor equity and its squishier cousin, the Paris Club’s principle of comparability of treatment across creditor groups.[20] More complexity and more legal interventions are likely to come.

It bears emphasis in this context that the sanctions, licenses, and asset protection measures shaping Venezuela’s debt talks are more narrowly tailored than similar measures that had shaped Iraq’s debt settlement following the ouster of Saddam Hussein.[21] Residents of certain countries such as China are excluded from the licenses;[22] meanwhile, asset protection extends only to those Venezuelan hydrocarbon proceeds held by or paid to the United States.[23] The net result so far is to give the United States considerable leverage in the coming negotiations between Venezuela and its creditors.

What Happens Next

The issuance of GL58 is an early precursor to restructuring, with a long way to go before its start. Venezuela will need to hire advisors, assess the full scope of its debt, establish a negotiating framework, and work through competing claims from bondholders, bilateral lenders, arbitral award-holders, oil companies, and a long queue of judgment creditors. That process cannot begin in earnest until there is a more complete picture of what Venezuela owes, to whom, on what terms, and in what priority.

That picture does not currently exist. Venezuela has not completed an IMF Article IV consultation since 2004—though on April 16, 2026, the IMF announced the resumption of dealings with Venezuela.[24] Beyond the absence of macroeconomic data, the underlying debt instruments are scattered across jurisdictions, partially disclosed, or simply never published.

Iraq’s experience is instructive: like Venezuela, Iraq emerged from an era of sanctions without a current IMF assessment, and its creditor universe was similarly complicated, as the line between its government obligations and state-owned enterprises was blurred. It took Ernst & Young and Citigroup more than a year to develop a workable picture of Iraq’s debt stock.[25] Until the #PublicDebtIsPublic experiment, no centralized public repository of the source documents for Venezuela’s debt existed at all. The Venezuelan Debt Documentation page we built demonstrates how consolidating publicly available transaction documents in one place enables more comprehensive review, surfaces connections between instruments, and illuminates their implications. None of this is possible when contracts remain scattered across jurisdictions and buried in court filings, which is why the page remains a live document: our multilingual collection and analysis effort—in English, Spanish, Portuguese, French, and Russian—is ongoing.

In sum, Venezuela’s debt stock is complicated, but far from unique or uniquely opaque. To the contrary, it is unusual in that its debt stock is so visible, so well-litigated, and so consequential that it is forcing the world to confront the obvious: that a credible sovereign debt restructuring requires more than numbers and haircuts, but legal infrastructure, information infrastructure, and political will. Without a complete picture of who holds what claims, on what terms, and in what priority, any exchange offer or negotiated restructuring risks being legally infirm: priority analyses become contested, intercreditor equity claims multiply, and the debtor cannot make the robust disclosures that a lawful and durable settlement requires.

The stakes of transparency extend beyond any single restructuring. When the terms of public borrowing are accessible to all, citizens, legislators, and oversight bodies can hold governments accountable for the obligations incurred in their name—a prerequisite for meaningful democratic control over public finance, and for ensuring that the costs of sovereign debt are not simply passed on to future generations in the dark.

The #PublicDebtIsPublic platform, a Sovereign Debt Forum initiative hosted at Georgetown Law, maintains a living database of primary source documentation for claims against Venezuela at https://publicdebtispublic.mdi.georgetown.edu/wp/resources/venezuela-debt-documentation-agreements-awards-and-judgments/.

[1] Nicolle Yapur & Maria Elena Vizcaino, Venezuela Kickstarts $170 Billion Debt Restructuring Process, Bloomberg (May 13, 2026, updated May 13, 2026), https://www.bloomberg.com/news/articles/2026-05-13/venezuela-government-announces-debt-restructuring-process.

[2] Reuters, “Venezuela’s Billions in Distressed Debt: Who Is in Line to Collect,” January 4, 2026, https://www.reuters.com/world/americas/venezuelas-billions-distressed-debt-who-is-line-collect-2026-01-04/. S&P Global Ratings, “The Venezuelan Sovereign Debt Restructuring Question,” April 27, 2026, https://www.spglobal.com/ratings/en/regulatory/article/the-venezuelan-sovereign-debt-restructuring-question-s101678814.

[3] Reuters, “Venezuela’s Billions in Distressed Debt: Who Is in Line to Collect,” January 4, 2026, https://www.reuters.com/world/americas/venezuelas-billions-distressed-debt-who-is-line-collect-2026-01-04/. See also Elias Ferrer, “Venezuela’s Long and Winding Debt Restructuring Road,” Financial Times, May 31, 2024, https://www.ft.com/content/629ba3b7-2e4b-49d7-9d00-e70e7cb4f3af.

[4] See also Venezuela Debt Documentation: Agreements, Awards, and Judgments, #PublicDebtIsPublic, https://publicdebtispublic.mdi.georgetown.edu/wp/resources/venezuela/.

[5] A careful study of Venezuela’s domestic legal framework is necessary. See Articles 150 and 312 of the Venezuelan Constitution and Hernández G., José Ignacio. “The Legal Implications of the May 13, 2026, Statement on the Restructuring of Venezuelan Debt.” May 14, 2026. https://www.joseignaciohernandezg.com/documents/the-legal-implications-of-the-may-13-2026-statement-on-the-restructuring-of-venezuelan-debt/.

[6] Venezuela has not completed an IMF Article IV consultation since 2004. The IMF Board did not formally censure Venezuela for its failure to comply with data reporting obligations until 2018. On April 16, 2026, the IMF announced the resumption of dealings with Venezuela, marking the first significant re-engagement in over two decades.

[7] World Bank, Radical [Debt] Transparency (2025), p. 9 (borrower primary responsibility); p. 21 (creditor reporting limited and inconsistent).

[8] Corporación Andina de Fomento.

[9] Crystallex Int’l Corp. v. Bolivarian Republic of Venezuela, 932 F.3d 126 (3d Cir. 2019) (Crystallex II). An entity is the alter ego of a foreign sovereign when the sovereign exerts such extensive control over the entity’s day-to-day operations that a principal-agent relationship is created, or when treating the two as separate would work a fraud or injustice. Crystallex Int’l Corp. v. Bolivarian Republic of Venezuela, 333 F. Supp. 3d 380, 397 (D. Del. 2018) (citing First Nat’l City Bank v. Banco Para El Comercio Exterior de Cuba, 462 U.S. 611, 628-29 (1983))

[10]Crystallex International Corporation v. Bolivarian Republic of Venezuela, 1:17-mc-00151, (D. Del. Nov 25, 2025) ECF No. 2553, p.7. Collin Eaton & Jared Malsin, Citgo Is a Crown Jewel of Venezuela’s Oil Industry. Elliott Is Set to Reap the Benefits., Wall St. J., Jan. 6, 2026, https://www.wsj.com/business/energy-oil/venezuela-citgo-oil-elliott-management-f433bb8c.

[11] Petróleos de Venezuela S.A. v. MUFG Union Bank, N.A., New York Court of Appeals, 41 N.Y.3d 462, February 20, 2024 (Venezuelan law governs).

[12] Petroleos de Venezuela S.A. v. MUFG Union Bank, N.A., No. 1:19-cv-10023-KPF (S.D.N.Y. Sept. 18, 2025). Richard Cooper, Boaz Morag & Miranda Herzog, $2B PDVSA Ruling Offers Insight Into Foreign-Issued Debt, Law360 (Oct. 27, 2025). Petroleos de Venezuela S.A. v. MUFG Union Bank, N.A., No. 25-2652 (2d Cir., Notice of Appeal filed Oct. 23, 2025).

[13] Petróleos de Venezuela S.A. v. MUFG Union Bank, N.A., No. 19 Civ. 10023 (KPF), 2025 WL 2675871 (S.D.N.Y. Sept. 18, 2025)

[14] Crystallex International Corporation v. Bolivarian Republic of Venezuela, U.S. District Court, District of Delaware, November 25, 2025, Case No. 1:17-mc-00151-LPS, ECF No. 2553 (Not Reported in Fed. Supp.) (Stark, J.). Benoît Morenne, “Citgo Is a Crown Jewel of Venezuela’s Oil Industry. Elliott Is Set to Reap the Benefits,” Wall Street Journal, January 5, 2026. (Amber Energy’s bid included “a headline price of $5.892 billion as well as an agreement to pay the 2020 Bondholders $2.125 billion in exchange for their support of the Amber Bid… and an $75 million in cash in exchange for extinguishment of $500 million of Gold Reserve’s attached judgment (which Gold Reserve did not accept”), pp. 129-130.

[15] Per General License 5W, Citgo Petroleum is protected from creditors through June 19, 2026. Five separate notices of appeal were filed on December 1, 2025, and docketed by the Third Circuit as follows: No. 25-3347 (Bolivarian Republic of Venezuela), No. 25-3348 (PDV Holding, Inc.), No. 25-3349 (CITGO Petroleum Corporation), No. 25-3350 (Petróleos de Venezuela, S.A.), and No. 25-3363 (Gold Reserve Inc.).

[17] Third Amendment to the Joint Financing Fund Agreement dated September 22, 2013 between the Government of the Bolivarian Republic of Venezuela and the Government of the People’s Republic of China dated July 21, 2014. The Fourth Amendment to the Joint Financing Fund Agreement dated July 21, 2014 between the Government of the Bolivarian Republic of Venezuela and the Government of the People’s Republic of China dated October 10, 2014 replaces the fixed daily barrel commitments with a flexible formula: Venezuela must deliver enough barrels per day to generate sufficient revenue to satisfy China Development Bank’s specific credit support requirements at any given time. The exact barrel number is to be confirmed in diplomatic notes exchanged between the parties, and is binding. Venezuela may deliver additional barrels if the confirmed amount is insufficient to meet loan obligations.

[18] Framework Agreement between Banco de Desarrollo Económico y Social de Venezuela (BANDES), Petróleos de Venezuela S.A., China National United Oil Corporation, China Development Bank Corporation, El Fondo de Desarrollo Nacional S.A., the Ministry of People’s Power for Planning and Finance of the Bolivarian Republic of Venezuela, and the Ministry of People’s Power for Energy and Petroleum of the Bolivarian Republic of Venezuela dated March 18, 2011.

[19] Oshin Pandey and Pavan Raghavendra, “How China’s Oil-Backed Lending in Venezuela Fell into Distress — and What Might Come Next,” AidData, January 23, 2026, https://www.aiddata.org/blog/how-chinas-oil-backed-lending-in-venezuela-fell-into-distress (citing AidData, China’s Global Loans and Grants Dataset, Version 1.0, Project No. 35985, https://china.aiddata.org/projects/35985).

[20] Comparability also applies to restructurings in the G-20 Common Framework for Debt Treatments beyond the DSSI, which involve a broader set of creditors but only low-income debtors. The national income criterion would exclude Venezuela.

[21] Executive Order No. 13303, “Protecting the Development Fund for Iraq and Certain Other Property in Which Iraq Has an Interest,” 68 Fed. Reg. 31931 (May 28, 2003), https://www.federalregister.gov/documents/2003/05/28/03-13412/protecting-the-development-fund-for-iraq-and-certain-other-property-in-which-iraq-has-an-interest. Section 1(b): “ Unless licensed or otherwise authorized pursuant to this order, any attachment, judgment, decree, lien, execution, garnishment, or other judicial process is prohibited, and shall be deemed null and void, with respect to… all Iraqi petroleum and petroleum products, and interests therein, and proceeds, obligations, or any financial instruments of any nature whatsoever arising from or related to the sale or marketing thereof, and interests therein, in which any foreign country or a national thereof has any interest, that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of United States persons.” Compare this to Executive Order No. 14373, “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People,” 91 Fed. Reg. 2045 (Jan. 15, 2026), https://www.federalregister.gov/documents/2026/01/15/2026-00831/safeguarding-venezuelan-oil-revenue-for-the-good-of-the-american-and-venezuelan-people. Section 3(a)” “Unless licensed or otherwise authorized pursuant to this order, any attachment, judgment, decree, lien, execution, garnishment, or other judicial process is prohibited, and shall be deemed null and void, with respect to the Foreign Government Deposit Funds,” which is defined as “funds paid to or held by the United States Government in designated United States Department of the Treasury accounts or funds on behalf of the Government of Venezuela or its agencies or instrumentalities, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A., that are derived from either the sale of natural resources from, or the sale of diluents to, the Government of Venezuela or its agencies or instrumentalities.” EO 13303 Section 1(b) appears broader, casting a net over all Iraqi petroleum and petroleum products once it touches U.S. jurisdiction or U.S. persons. EO 14373 3(a) appears narrower as it only protects funds once they have already landed in a designated Treasury account. GL 52 and 58?)

[22] See e.g. General License No. 52: Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A., March 18, 2026 and General License No. 58: Authorizing Certain Services to the Government of Venezuela in Connection with Potential Debt Restructuring, May 5, 2026.

[23] See Executive Order 14373: Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People, January 15, 2026.

[24] See World Economic Outlook Statistical Appendix, October 2025. The IMF Board only issued a formal censure for the Venezuelan government’s failure to comply with its data reporting obligations in 2018. See IMF Executive Board Statement on Venezuela, May 2, 2018. IMF Announces Resumption of Dealings with Venezuela, Press Release No. 26/123, April 16, 2026.

[25] The Iraqi government retained two U.S. companies, Ernst and Young and Citigroup, to adjudicate these debt claims and to help negotiate various settlements with small and large Iraqi creditors. The Iraq Debt Reconciliation Office was established in Amman, Jordan in May 2004. On July 26, 2005, Iraq proposed a comprehensive settlement of its commercial claims on terms comparable to those agreed with the Paris Club. Martin A. Weiss, “Iraq’s Debt Relief: Procedure and Potential Implications for International Debt Relief,” CRS Report RL33376 (Washington, DC: Congressional Research Service, March 29, 2011).