Venezuela Debt Documentation: Agreements, Awards, and Judgments  

• Loan Agreement between the Republic of Venezuela and International Bank for Reconstruction and Development dated December 14, 1990
• Loan Agreement between the Republic of Venezuela and International Bank for Reconstruction and Development dated October 12, 1995
• Loan Agreement between the Republic of Venezuela and International Bank for Reconstruction and Development dated October 12, 1995
• Loan Agreement between the Republic of Venezuela and the International Bank for Reconstruction and Development dated October 12, 1995
• Term Loan Agreement between CITGO Petroleum Corporation and Credit Suisse dated February 27, 2003
• Loan Agreement between the Republic of Venezuela and Inter American Development Bank dated November 14, 2006
• Joint Financing Fund Agreement between the Government of the Bolivarian Republic of Venezuela and the Government of the People’s Republic of China dated May 9, 2008
  • Second Amendment to the Joint Financing Agreement dated February 18, 2009 between the Government of the Bolivarian Republic of Venezuela and the Government of the People’s Republic of China dated February 27, 2012
  • 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
  • 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
• Loan Agreement between the Republic of Venezuela and Inter American Development Bank dated August 19, 2008
• Agreement between the Government of the Russian Federation and the Government of the Bolivarian Republic of Venezuela on the establishment of the Russian-Venezuelan Bank dated June 23, 2009
  • Amendment to the Agreement dated June 23, 2009 between the Government of the Russian Federation and the Government of the Bolivarian Republic of Venezuela on the establishment of the Russian-Venezuelan Bank dated April 2, 2010
• Loan Agreement between the Republic of Venezuela and Inter American Development Bank dated December 30, 2009
• Loan Agreement between the Government of the Bolivarian Republic of Venezuela and the Government of the People’s Republic of China dated September 10, 2010
• Loan Agreement between the Republic of Venezuela and Inter American Development Bank dated September 30, 2010
• Loan Agreement between the Republic of Venezuela and Inter American Development Bank (Waste, No. 2322/OC-VE) dated December 21, 2010
• Loan Agreement between the Republic of Venezuela and Inter American Development Bank (Water, No. 2292/OC-VE) dated December 21, 2010
  • Loan Agreement between the Republic of Venezuela and Inter American Development Bank dated December 21, 2010, Amendment No. 1 dated May 15, 2014
• Four Party Agreement between Banco de Desarrollo Económico y Social de Venezuela, Petróleos de Venezuela S.A., China National United Oil Corporation, and China Development Bank Corporation dated March 18, 2011
  • Petroleum Sales and Purchase Contract between Petróleos de Venezuela S.A. and China National United Oil Corporation dated March 2011
  • Account Management Agreement between Banco de Desarrollo Económico y Social de Venezuela and China Development Bank Corporation dated March 2011
  • 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
• Loan Agreement between the Government of the Russian Federation and the Government of the Bolivarian Republic of Venezuela dated December 8, 2011
• Loan Agreement between the Republic of Venezuela and Inter American Development Bank dated December 28, 2011
  • Loan Agreement between the Republic of Venezuela and Inter American Development Bank dated December 28, 2011, Amendment No. 1 dated May 15, 2014
• Loan Agreement between the Republic of Venezuela and Inter American Development Bank dated December 27, 2012

View the list on the #PublicDebtIsPublic platform.

• Fiscal Agency Agreement between The Republic of Venezuela and The Chase Manhattan Bank, dated August 6, 1998
  • Amendment No. 2 to Fiscal Agency Agreement dated August 6, 1998 Bolivarian Republic of Venezuela (September 29, 2004)
• Prospectus Petróleos de Venezuela, S.A. Notes (July 19, 2001)
• Indenture CITGO Petroleum Corporation Notes due 2011 (February 27, 2003)
• Prospectus CITGO Petroleum Corporation (Exchange Offer) Notes due 2011 (September 9, 2003)
• Prospectus Supplement Bolivarian Republic of Venezuela Bonds due 2034 (January 7, 2004)
• Prospectus Supplement to Prospectus dated February 11, 2004 (Exchange Offer) Bolivarian Republic of Venezuela Notes due 2013 (February 11, 2004)
• Prospectus Bolivarian Republic of Venezuela Debt Securities (September 21, 2004)
  • Prospectus Supplement to Prospectus dated September 21, 2004 Bolivarian Republic of Venezuela Notes due 2015 (September 21, 2004)
  • Prospectus Supplement to Prospectus dated September 21, 2004 (Exchange Offer) Bolivarian Republic of Venezuela Bonds due 2007, 2008 (September 22, 2004)
  • Prospectus Supplement to Prospectus dated September 21, 2004 Bolivarian Republic of Venezuela Bonds due 2034 (December 3, 2004)
  • Prospectus Supplement to Prospectus dated September 21, 2004 Bolivarian Republic of Venezuela Bonds due 2015 (March 7, 2005)
• Supplement to Prospectus Supplement dated September 29, 2004 Bolivarian Republic of Venezuela Bonds due 2014 (October 6, 2004)
• Indenture CITGO Petroleum Corporation Notes due 2011 (October 22, 2004)
• Prospectus Supplement Bolivarian Republic of Venezuela USD-denominated bonds due 2034 (December 3, 2004)
  • Supplement to Prospectus Supplement dated December 3, 2024 Bolivarian Republic of Venezuela Bonds due 2034 (December 9, 2004)
• Listing Memorandum for Bolivarian Republic of Venezuela Bonds due 2038 (November 29, 2007)
• Listing Memorandum for Bolivarian Republic of Venezuela Bonds due 2038 (November 30, 2007)
• Prospectus Petróleos de Venezuela, S.A. Notes due 2017, 2027, 2037 (December 4, 2007)
• Listing Memorandum for Bolivarian Republic of Venezuela Bonds due 2023 and 2028 (May 9, 2008)
• Listing Memorandum for Bolivarian Republic of Venezuela Bonds due 2031 (August 5, 2011)
• Listing Memorandum for Bolivarian Republic of Venezuela Bonds due 2026 (October 21, 2011)
• Indenture Petroleos de Venezuela S.A. (Issuer), PDVSA Petroleo, S.A. (Guarantor), Wilmington Trust Company (Trustee), Citibank (Registrar, Transfer Agent and Principal Paying Agent), and Dexia Banque Internationale à Luxembourg S.A. (Listing Agent and Paying Agent) Notes due 2021 (November 17, 2011)
• Prospectus Supplement to Prospectus dated September 21, 2014  Bolivarian Republic of Venezuela Bonds due 2014 (September 29, 2014)
• Offering Circular Petroleos de Venezuela, S.A. Notes due 2017 (September 16, 2016) and Pledge and Security Agreement among PDV Holding (Pledgor), Petroleos de Venezuela S.A. (Issuer), PDVSA Petroleo, S.A. (Guarantor), GLAS Americas LLC (Collateral Agent), and MUFG Union Bank (Trustee) (October 2016) 
  • Indenture Petroleos de Venezuela S.A. Notes due 2020 (October 2016) (PDVSA Petroleo, S.A. as Guarantor)
• Credit Agreement among Petroleos de Venezuela S.A. (Borrower), PDVSA Petroleo S.A. (Guarantor), and GE Capital EFS Financing, Inc. (Agent) (December 27, 2016)
• Note Agreement among Petroleos de Venezuela S.A. (Issuer), PDVSA Petroleo S.A. (Guarantor), Dresser-Rand Company (Initial Noteholder), and Dresser-Rand Company (Administrative Agent) Note Series 2017B (January 20, 2017)

View the list on the #PublicDebtIsPublic platform.

Claims against the Bolivarian Republic of Venezuela

PDVSA – Coming soon!

Other Agencies or Instrumentalities of Venezuela – Coming soon!

Bolivarian Republic of Venezuela

PDVSA

Other Agencies or Instrumentalities of Venezuela – Coming soon!

Bolivarian Republic of Venezuela

• Venezuela US SRL [“VUS”] v. Bolivarian Republic of Venezuela
  • Exposure: ~$US138 million
  • U.S. District Court, District of Columbia. June 09, 2025 789 F.Supp.3d 1 (Federal trial court granted VUS’ petition for recognition and enforcement of a foreign arbitral award against Venezuela under the New York Convention)
  • Related to:
    • Venezuela US, S.R.L. v. Bolivarian Republic of Venezuela, PCA Case No. 2013-34, Final Award (Quantum), November 4, 2022

• OI European Group B.V. v. Bolivarian Republic of Venezuela
  • Exposure: ~$US582.2 million
  • U.S. Court of Appeals, Third Circuit. July 07, 2023 73 F.4th 157 (Appendix A) (Federal appellate court affirms lower court decision that holders of judgments and arbitration awards against Venezuela may enforce them against PDVSA property because PDVSA is the sovereign’s alter ego)
  • U.S. District Court, District of Delaware. March 23, 2023 663 F.Supp.3d 406 (Appendix B) (Federal trial court holds that creditors of Venezuela may enforce them against PDVSA property because PDVSA is the sovereign’s alter ego for the relevant purposes, notwithstanding political and government changes)
  • U.S. District Court, District of Columbia, May 21, 2019 Case 1:16-cv-01533-ABJ Not Reported in Fed. Supp. (Federal trial court granted OIEG’s motion for summary judgment and confirmed an ICSID arbitration award of over $400 million against Venezuela.)

• Crystallex International Corporation v. Bolivarian Republic of Venezuela
  • Exposure: ~$US1.2 billion
  • U.S. District Court, District of Columbia. March 25, 2017 244 F.Supp.3d 100 (Federal trial court granted Crystallex’s Petition to Confirm Arbitral Award in Crystallex International Corporation v. Bolivarian Republic of Venezuela, ICSID Case No. ARB(AF)/11/2)
  • U.S. District Court, District of Delaware (Crystallex registered the confirmation of its award at the District of Delaware and sought to execute its US$1.2 billion judgment against the shares of PDV Holding, Inc. (PDVH))
    • See Final Priority Order, Crystallex Int’l Corp. v. Bolivarian Republic of Venezuela, U.S. Court, District of Delaware, April 3, 2024 Case 1:17-mc-00151-LPS Not Reported in Fed. Supp.
    • See also Indenture Petroleos de Venezuela S.A. Notes due 2020 (October 2016)
  • U.S. District Court, District of Delaware. August 09, 2018 333 F.Supp.3d 380 (Federal court held that PDVSA is the alter ego of Venezuela under the Bancec extensive control test, and so Crystallex could attach PDVSA’s shares in PDV Holding, Inc. (PDVH) to satisfy its US$1.2 billion judgment against Venezuela.)
  • Related to:
    • Crystallex International Corp. v. Bolivarian Republic of Venezuela, U.S. District Court, District of Delaware (Also known as the Crystallex Asset Proceedings)
    • U.S. Court of Appeals, Third Circuit, July 29, 2019 932 F.3d 126 (Federal appellate court affirms the Delaware District Court’s order holding that PDVSA is Venezuela’s alter ego and to attach PDVSA’s assets to satisfy Crystallex’s judgment against Venezuela.)

• • Related to:
    • Crystallex v PDVH, U.S. District Court, District of Delaware. December 12, 2019 Cases: 1:15-cv-01082-LPS et al. Not Reported in Fed. Supp. (Federal trial court granted motions to intervene by Rosneft, CITGO, and certain bondholders, but denied OI European Group’s motion for a writ of attachment, holding that collateral estoppel did not apply to the alter ego finding from the Crystallex proceeding and that each creditor must independently prove PDVSA is Venezuela’s alter ego.
    • Crystallex v Venezuela, U.S. Court of Appeals, Third Circuit. July 09, 2024 Case 23-1117 Not Reported in Fed. Rptr. (Federal appellate court affirmed the trial court’s denial of Red Tree Investments, LLC’s motion to intervene in Crystallex’s action against PDVH)
• Tidewater Investment SRL v. Bolivarian Republic of Venezuela

• • Exposure: ~$US2.3 billion
  • U.S. District Court, District of Delaware, November 01, 2003 Case 1:2022mc00263 – Document 73 Not Reported in Fed. Supp. (Federal district court found in favor of the seven creditors who sought to attach shares of PDV Holding, Inc. (PDVH) owned by Petróleos de Venezuela, S.A. (PDVSA) to satisfy their existing judgments against Venezuela.)
  • Related to: (Underlying actions from the following seven creditors)
    • Contrarian Capital Mgmt., L.L.C. v. Bolivarian Republic of Venezuela, U.S. District Court, S.D.N.Y., Case 1:19-cv-11018 Not Reported in Fed. Supp.
      • Exposure: ~$US58 million (See here)
    • Valores Mundiales, S.L. et al. v. Bolivarian Republic of Venezuela U.S. District Court, District of Delaware, Case 1:23-mc-00298-LPS Not Reported in Fed. Supp.
      • Exposure: ~$US436 million (See here)
      • Related to: Valores Mundiales, S.L. v. Bolivarian Republic of Venezuela, ICSID Case No. ARB/13/11, Award (July 25, 2017)
  • Pharo Gaia Fund, Ltd. et al. v. Bolivarian Republic of Venezuela U.S. District Court, S.D.N.Y., Case 1:20-cv-08497 Not Reported in Fed. Supp.
    • Exposure: ~$US1.4 billion (See here)
  • Gramercy Distressed Opportunity Fund LLC v. Bolivarian Republic of Venezuela, U.S. District Court, District of Delaware, Cases 23-378-LPS & 23-379-LPS Not Reported in Fed. Supp.
    • Exposure: ~$US281 million (See here)
    • Related to: Tenaris S.A. v. Bolivarian Republic of Venezuela, U.S. District Court, District of Columbia, Case No. 1:18-cv-01373-CJN Not Reported in Fed. Supp.
  • Saint-Gobain Performance Plastics Europe v. Bolivarian Republic of Venezuela, U.S. District Court, District of Delaware, Case 1:23-mc-00397-LPS Not Reported in Fed. Supp.
    • Exposure: ~$US44 million (See here)
    • Related to: Saint-Gobain Performance Plastics Europe v. Bolivarian Republic of Venezuela, U.S. District Court, District of Delaware, Case 1:20-cv-00129-RC Not Reported in Fedd. Supp.

PDVSA

• Dresser-Rand Company [now Siemens Energy, Inc.] v. Petróleos de Venezuela, S.A. et al [1]
  • Exposure: ~US$150 million
  • U.S. District Court, S.D.N.Y., February 11, 2020 439 F.Supp.3d 270 (Federal trial court granted Dresser-Rand’s motion for summary judgment for the balance due under a 2017 Note Agreement issued by PDVSA and guaranteed by PDVSA Petróleo, S.A.)
  • U.S. Court of Appeals, Second Circuit, August 02, 2021 Case 1:19-cv-02689 Not Reported in Fedd. Supp. (Federal appellate court affirmed the trial court’s partial summary judgment, holding that the broad, unconditional guarantee and defense-waiver provisions in Article VI of the Note Agreement effectively waived Petróleo’s impossibility defense based on U.S. sanctions.)
  • U.S. District Court, S.D.N.Y., December 08, 2021 574 F.Supp.3d 217  (Federal trial court found that the doctrine of impossibility did not discharge PDVSA from performing its contractual obligations.)
  • U.S. Court of Appeals, Second Circuit. September 20, 2023. 82 F.4th 144 (Federal appeals court affirmed the federal trial court’s finding that it was not impossible for PDVSA to make payments.)

1. 1. See Siemens Energy, Inc. v. Petróleos de Venezuela, S.A., U.S. Court of Appeals, Second Circuit. September 20, 2023. 82 F.4th 144. Footnote 1: “While this appeal was pending, Dresser-Rand Co. agreed to merge with Siemens Energy, Inc. (“Siemens”). Dkt. No. 77 at 1. In anticipation of the merger, Dresser-Rand assigned the judgment at issue in this appeal to Siemens and filed a motion for Siemens to be substituted as Plaintiff-Appellee pursuant to Federal Rule of Appellate Procedure 43(b), id., which we granted, Dkt. No. 80. For purposes of this opinion, we refer to Dresser-Rand when recounting the factual and legal history of the case but note that, today, Siemens is the real party in interest.”

• PDV Sweeny, Inc. v. ConocoPhillips Company, U.S. District Court, S.D.N.Y.
  • Exposure: ~US$11 million
  • U.S. District Court, S.D.N.Y., September 01, 2015 Case 1:14-cv-5183-AJN Not Reported in Fed. Supp. (Federal trial court granted ConocoPhillips’ petition to confirm, recognize, and enforce PDV Sweeny, Inc. v. ConocoPhillips Co., ICC Case No. 16982/JRF/CA/ASM (C-17336/JRF), Final Award (Aug. 18, 2014))

• Petróleos de Venezuela, SA, PDVSA Petróleo, SA, and PDV Holding, Inc v. MUFG Union Bank, N.A. [trustee] and GLAS Americas LLC [collateral agent]
  • Potential exposure: $2-3 billion, 50.1% stake in Citgo
  • Petroleos De Venezuela S.A. v. MUFG Union Bank, N.A., U.S. District Court, S.D.N.Y. (Federal trial court considers whether ~US$1.7 billion in debt instruments, the “2017 Notes” and “2020 Notes”, issued by Venezuela’s state-owned oil company, PDVSA, secured by a pledge of 50.1% of CITGO Holding, are valid and enforceable)
    • Primary Debt Instruments:
      • Note Agreement among Petroleos de Venezuela S.A. (Issuer), PDVSA Petroleo S.A. (Guarantor), Dresser-Rand Company (Initial Noteholder), and Dresser-Rand Company (Administrative Agent) Note Series 2017B (January 20, 2017)
      • Indenture for 2020 Notes (VEN121 to be uploaded)
      • Offering Circular for the 2020 Notes (VEN117 to be uploaded)
        • Supplement to the Offering Circular (VEN60 to be uploaded)
      • Pledge and Security Agreement between PDVH (as pledgor), PDVSA Petróleo (as guarantor), GLAS (as collateral agent), and MUFG (as trustee), pledging 50.1% of the equity in CITGO Holding (VEN60 to be uploaded)
    • Relevant domestic law:
      • Constitution of the Bolivarian Republic of Venezuela, Art. 303
      • National Assembly Resolution dated Feb. 13, 2019
      • National Assembly Resolution dated Sept. 27, 2016
      • National Assembly Resolution dated Oct. 15, 2019
  • U.S. District Court, S.D.N.Y., October 16, 2020, 495 F. Supp. 3d 257 (Federal trial court issues summary judgment for the creditors, holding that New York law governs questions of validity of the notes and the CITGO collateral pledge, and that the act-of-state doctrine did not apply
  • U.S. Court of Appeals, Second Circuit, October 13, 2022 51 F.4th 456 (Appellate court certifies questions of whether New York or Venezuelan law governs the validity of the notes to the highest court in New York State)
  • New York Court of Appeals, February 20, 2024 41 N.Y.3d 462 (New York State court holds that under New York law, Venezuelan law governs)
  • U.S. Court of Appeals, S.D.N.Y., July 3, 2024 N106 F.4th 263 (Federal appellate court vacates the the federal trial court decision, which had declared the Notes to be valid and enforceable, because the New York Court of Appeals held that Venezuelan law—not New York law—governs the validity of the 2020 Notes and the federal trail court had applied New York law and deemed Venezuelan constitutional requirements irrelevant, which was erroneous)
  • U.S. District Court, S.D.N.Y., September 18, 2025 Case 1:2019cv10023 – Document 397 Not Reported in Fed. Supp. (Federal trial court, on remand, holds that notes are valid under Venezuelan law; final judgment here; enforcement stayed on November 14, 2025, pending selection of willing bidder for PDVH in Crystallex International Corporation v. Bolivarian Republic of Venezuela, U.S. District Court, District of Delaware; further stay pending appeal denied here on December 5, 2025)

• Helmerich & Payne International Drilling Co. v. Bolivarian Republic of Venezuela and Petróleos de Venezuela, S.A. and PDVSA Petroleo, S.A.
  • Exposure: ~$US100 million
  • U.S. District Court, District of Columbia, September 20, 2013 971 F.Supp.2d 49 2013 (Venezuela) (Federal trial court granted Venezuela’s motion to dismiss the subsidiary’s expropriation claim, but denied the motion in all other respects.)
  • U.S. Court of Appeals, DC Circuit, May 01, 2015 784 F.3d 804 (Venezuela) (Federal appellate court found that the federal trial court correctly concluded that the parent corporation had sufficient rights in its subsidiary’s property to support its expropriation claim, but should have also allowed the subsidiary’s claim to proceed.)
  • U.S. District Court, District of Columbia, May 13, 2016 185 F.Supp.3d 233 (Venezuela) (Federal trial court deferred the issue of whether Venezuela is a proper defendant and ordered Venezuela to participate in discovery in the meantime.)
  • Supreme Court of the United States, May 01, 2017 581 U.S. 170 137 S.Ct. 1312 (Venezuela) (Supreme Court held that the FSIA’s expropriation exception requires a court to actually determine — not just find arguable — that the property at issue was “taken in violation of international law” before stripping a foreign sovereign of immunity.)
  • U.S. Court of Appeals, DC Circuit. August 07, 2018 743 Fed.Appx. 442 (Venezuela) (Federal appellate court held that only the American parent of Helmerich, not its Venezuelan subsidiary, had suffered a taking in violation of international law, and affirmed the trial court’s dismissal of the subsidiary’s claims.)
  • U.S. Court of Appeals, DC Circuit January 31, 2023 Case 1:11-cv-01735-CRC Not Reported in Fed. Supp. (Venezuela) (Federal appellate court dismisses Venezuela for lack of subject matter jurisdiction.)
  • U.S. District Court, District of Columbia. September 20, 2024 754 F.Supp.3d 29 (PDVSA) (Federal trial court denied PDVSA’s motion to dismiss on all three grounds: (i) subject matter jurisdiction, (ii) personal jurisdiction, and (iii) act-of-state doctrine.)
  • U.S. Court of Appeals, DC Circuit, October 03, 2025 153 F.4th 1316 (PDVSA) (Federal appellate court affirmed the denial of PDVSA’s motion to dismiss Helmerich & Payne’s expropriation claim on all grounds.)
• Lovati v. Petroleos De Venezuela, S.A. U.S. District Court, S.D.N.Y., Case 1:19-cv-04799 Not Reported in Fed. Supp.
  • Exposure: ~$US85 million (See here)
  • U.S. District Court, S.D.N.Y., March 28, 2025, Case No. 1:19-cv-04799-ALC Not Reported in Fed. Supp. (Federal trial court denied both parties’ cross-motions for summary judgment, finding a genuine issue of material fact as to whether U.S. sanctions rendered PDVSA’s payment obligations under the notes impossible to perform. This is distinguished from the dismissals at the summary judgment level in Dresser-Rand and Red Tree)
  • Related to: Prospectus Petróleos de Venezuela, S.A. Notes due 2017, 2027, 2037 (December 4, 2007)
    • Dresser-Rand [now Siemens Energy, Inc.] v. Petróleos de Venezuela, S.A. U.S. District Court, S.D.N.Y., December 8, 2021, 574 F.Supp.3d 217 and U.S. Court of Appeals, Second Circuit, September 20, 2023, 82 F.4th 144.
    • Red Tree Investments, LLC v. Petróleos de Venezuela, S.A. U.S. District Court, S.D.N.Y., November 29, 2022, Case No. 19-cv-2519. Not Reported in Fed. Supp.

• Crystallex International Corp. v. Petróleos De Venezuela, S.A.
  • U.S. Court of Appeals, Third Circuit. January 03, 2018 879 F.3d 79 (Appellate federal court reversed the federal trial court’s decision and found that PDVH did not engage in “fraudulent transfers” under the Delaware Uniform Fraudulent Transfer Act because it was not the debtor – even if Venezuela allegedly orchestrated a series of debt offerings and asset transfers among PDVSA, PDVH, CITGO Holding, and CITGO Petroleum.)

• G&A Strategic Investments I LLC v. Petróleos de Venezuela, S.A.
  • Exposure: ~US$1.44 billion
  • U.S. District Court, S.D.N.Y., February 21, 2026 Case 1:23-cv-10766-JSR not Reported in Fed. Supp. (Federal trial court denied PDVH Holding’s motion to dismiss the plaintiffs’ alter ego (veil-piercing) and turnover claims, finding that the plaintiffs had plausibly alleged that PDVH is the alter ego of PDVSA.)
  • Related to: G&A Strategic Investments I LLC, et al., v. Petróleos de Venezuela, S.A. and PDVSA Petróleo S.A., Case No. 23-cv-10766 and Red Tree Investments, LLC v. Petróleos de Venezuela, S.A. and PDVSA Petróleo S.A., Case No. 1:19-cv-2519-PKC [See Notice of Related Case]
• Girard Street Investment Holdings LLC v. PDV Holding, Inc.
  • Exposure: ~US$1 billion
  • U.S. District Court, S.D.N.Y., June 5, 2025 Case 1:23-cv-10772-JSR. Not Reported in Fed. Supp. (Federal trial court found that PDVSA and its subsidiary PPSA are jointly and severally liable on the promissory notes — the 2016 Halliburton Note and the 2017 Schlumberger Notes — which the plaintiffs had purchased at a discount from the original holders)
• Red Tree Investments, LLC v. Petróleos de Venezuela, S.A.
  • Exposure: ~US$246 million
  • U.S.. District Court, S.D.N.Y., November 29, 2022 Case No. 19-cv-2519. Not Reported in Fed. Supp. (The federal trial court found for Red Tree on two consolidated appeals arising from PDVSA’s default on a 2015 and 2016 Note Agreement and a 2016 Credit Agreement. PDVSA’s impossibility defense — that U.S. sanctions rendered payment impossible — was rejected; the court found that payment was not truly impossible and that sanctions were not unforeseeable when the agreements were executed. The Second Circuit affirmed.)
• Clion Limited v. PDVSA Petroleo S.A.
  • Exposure: ~US$610,000
  • U.S. District Court, District of Delaware, January 31, 2024, No. 23-1409-LPS. Not Reported in Fed. Supp. (The federal trial court issued a decision confirming and enforcing a foreign arbitral award against PDVSA Petróleo S.A.)
  • Related to: Clion Limited v. PDVSA Petroleo S.A. (II), First Partial Award, Ad hoc arbitration, April 14, 2023

Other Agencies or Instrumentalities of Venezuela – Coming soon!

BCV gold dispute litigation saga 

• Exposure: ~$2 billion. ~$120 million (gold swap contracts between Deutsche Bank and the Central Bank of Venezuela (BCV) + ~$1.95 billion (Venezuelan gold reserves held by the Bank of England).
  • Both sets of assets are frozen because two rival boards of the BCV — one loyal to Maduro, one appointed by Guaidó — are issuing contradictory instructions to UK financial institutions about what to do with the money.
• Deutsche Bank AG London Branch and others v Governor and Company of the Bank of England and others [2020] EWHC 1721 (Deutsche Bank was caught between competing instructions from the two BCV boards on where to send $120 million it owes. The High Court ruled decisively for the Guaidó Board, applying the “one voice” doctrine; because the UK government recognized Guaidó as Venezuela’s legitimate president, English courts must follow that lead and treat his appointees as the real BCV.)
• Maduro Board of the Central Bank of Venezuela v Guaidó Board of the Central Bank of Venezuela [2020] EWCA Civ 1249 (The Court of Appeal found that the UK government’s recognition of Guaidó wasn’t sufficiently clear and unambiguous to be treated as fully conclusive, and further clarification was needed before deciding who controls the assets.)
• Maduro Board of the Central Bank of Venezuela v Guaidó Board of the Central Bank of Venezuela [2021] UKSC 57 (The Supreme Court clarifies that the UK government had recognized Guaidó as constitutional interim president since February 2019 and had never recognized Maduro for any purpose. Under the “one voice” doctrine, English courts must therefore treat the Guaidó Board as the legitimate BCV. What about Venezuelan Supreme Tribunal (STJ) judgments that purport to declare Guaidó’s appointments invalid under Venezuelan law? Should English courts recognize those foreign judgments? This question was sent back to the Commercial Court.)
• A v B/Banco Central De Venezuela and Governor and Company of the Bank of England [2022] EWHC 2040 (Comm) (The High Court rules that the STJ judgments invalidating Guaidó’s BCV appointments should not be recognized in the UK, because doing so would directly contradict the UK government’s recognition of Guaidó. The Maduro Board cannot use Venezuelan court rulings to claw back authority that English law has already assigned to the Guaidó Board.)
• Deutsche Bank AG (London Branch) v Central Bank of Venezuela and receivers [2023] EWCA Civ 742 (The Court of Appeals upholds the High Court’s refusal to recognize the STJ judgments for the period when Guaidó was recognized, but remits the case back down to the Commercial Court for the question of what happens going forward in light of the changed recognition position. Permission to appeal to the Supreme Court was refused in November 2023.)
• Deutsche Bank AG, London Branch -and- Receivers Appointed by the Court -and- Central Bank of Venezuela [2023] EWHC 1942 (Comm) (The court-appointed receivers who have been holding the $120 million for years need to be paid, and the Maduro Board objects on state immunity grounds. The court rules the receivers can take their fees from the held funds regardless.)

PDVSA – unpaid loans

Banco San Juan Internacional Inc v Petróleos de Venezuela SA [2020] EWHC 2937 (Comm)

• Exposure: ~US$86 million (two English law‑governed credit agreements) (The High Court rejected the three principal defences raised by PDVSA arising out of U.S. sanctions (notably EO 13850 and EO 13884): (i) the “sanctions clause” in the agreements suspended its repayment obligations; (ii) performance was rendered illegal under the law of the place of performance (Ralli Bros doctrine); and (iii) the claimed default interest was an unenforceable penalty. The Court held that the sanctions clause was properly construed as a negative covenant benefiting the lender rather than a condition suspending repayment, that PDVSA had not demonstrated that a U.S. licence permitting payment would have been unavailable (so performance was not illegal or impossible), and that the default interest provision was a legitimate commercial bargain rather than a penalty. The court therefore granted summary judgment for the full amount claimed.)

PDVSA – unpaid invoices litigation

• Exposure: ~US$129 million (Standby letter of credit issued to secure payment of drilling services invoices.) 
  • In September 2010, Petrosaudi Oil Services Venezuela Ltd (“POS”) contracted with PDVSA to provide oil rig drilling services and a drilling vessel in Venezuela. PDVSA was required to pay invoices within 30 days. From January 2015, PDVSA stopped paying. POS is seeking repayment using an English law-governed standby letter of credit (“SBLC”) issued by Novo Banco guaranteeing payment of invoices, and an award from Paris-seated UNCITRAL arbitration
  • Related to: PDVSA Servicios S.A. v. PetroSaudi Oil Services Ltd., Ad hoc arbitration, Final Award (Operative Part), July 17, 2020).
• Petrosaudi Oil Services (Venezuela) LTD V Novo Banco S.A. and Others [2016] EWHC 2456 (Comm) (The High Court upheld the injunction obtained by PDVSA, which prevents Novo Banco from paying. The Court also found that in light of the findings of the tribunal in PDVSA Servicios S.A. v. PetroSaudi Oil Services Ltd., Ad hoc arbitration, applying Venezuelan law, the invoiced sums weren’t immediately due, meaning POS’s certificate stating PDVSA was “obligated to pay” was false and therefore, the fraud exception to the autonomy principle of letters of credit applied.)
• Petrosaudi Oil Services (Venezuela) LTD (a body corporate) V Novo Banco S.A. and Others [2017] EWCA Civ 9 (The Court of Appeal reviewed Petrosaudi’s appeal from the High Court decision above and overturned it, reinforcing the principle that banks must honour compliant demands under letters of credit absent clear fraud, even where underlying contractual disputes are ongoing. (i) PDVSA was under an obligation to pay invoices under the contract, notwithstanding disputes and the effect of Venezuelan law; (ii) the phrase “obligated to pay” was capable of referring to an accrued liability, not necessarily an immediately enforceable obligation; and (iii) the demand was not fraudulent, as Petrosaudi honestly believed it was entitled to payment. Reaffirming the autonomy principle of letters of credit and the narrow scope of the fraud exception, the court held that Petrosaudi was entitled to call on the SBLC and ordered payment of approximately US$129.8 million.)
• Exposure: ~US$300 million (Amount in an escrow account held by Clyde & Co LLP as escrow agent.) 
  • During the course of the arbitral proceedings in PDVSA Servicios S.A. v. PetroSaudi Oil Services Ltd., an Escrow Account was established into which were paid the proceeds of demands by POS under a standby letter of credit issued by a third-party bank in favour of POS. The Escrow Account was operated by Clyde & Co, and under the escrow agreement between the parties Clyde & Co agreed to instruct the bank at which the account was held to pay the sums in the Escrow Account at the direction of the arbitral tribunal.
  • Related to: PDVSA Servicios S.A. v. PetroSaudi Oil Services Ltd., Ad hoc arbitration, Final Award (Operative Part), July 17, 2020.
• PDVSA Servicious SA v Clyde & Co LLP and another [2020] EWHC 3297 (Ch) (The court granted summary judgment for the defendants, Clyde & Co and PetroSaudi, refusing to continue the interim injunction that had restrained Clyde from distributing ~$300 million in escrow funds to PetroSaudi.)
• PDVSA Servicious SA v Clyde & Co LLP and another [2020] EWHC 2322 (Ch) (The High Court refuses the joinder of National Crime Agency in PDVSA Servicios SA’s ongoing proceedings against Clyde & Co LLP and POS, finding the NCA’s stance under the Proceeds of Crime Act doesn’t create a justiciable issue requiring its presence.)

PDVSA – unpaid invoices litigation

• Exposure: ~US$12 billion (Breach of contract claim.) 
  • Mobil Cerro Negro Ltd, holding a 41.7% interest in the Cerro Negro Association in Venezuela, sought a worldwide freezing injunction under section 44 of the Arbitration Act 1996 in aid of a New York-seated ICC arbitration against PDVSA and PDVSA-CN (Mobil Corp. v. Petróleos de Venezuela, S.A. (PDVSA) and PDVSA Cerro Negro, S.A., ICC Case No. 15416/JRF/CA, Award (December 23, 2011)), arising from PDVSA’s nationalization of Mobil’s Orinoco Belt interests.
  • Related to: Mobil Corp. v. Bolivarian Republic of Venezuela, ICSID Case No. ARB/07/27 and Mobil Corp. v. Petróleos de Venezuela, S.A. (PDVSA) and PDVSA Cerro Negro, S.A., ICC Case No. 15416/JRF/CA, Award (December 23, 2011).

• Mobil Cerro Negro Ltd v Petroleos De Venezuela SA [2008] EWHC 532 (Comm) (The High Court set aside the worldwide freezing order and refused Mobil’s application to continue it. PDV succeeded on multiple independent grounds: (i) England had insufficient connection to the dispute or the assets (~US$570 million of PDVSA assets outside Venezuela/US); (ii) Mobil had failed to demonstrate a real risk of dissipation of assets; and (iii) the application lacked urgency.)

Other Agencies or Instrumentalities of Venezuela – Coming soon!

Bolivarian Republic of Venezuela – Coming soon!

PDVSA – Coming soon!

Other Agencies or Instrumentalities of Venezuela – Coming Soon!

Canada’s sanctions related to Venezuela.

European Council — Venezuela Sanctions Renewal (Dec. 2025, extending to Jan. 2027)

SECO — Venezuela Measures Page

UK — Venezuela Sanctions Guidance

• U.S. Department of State — Venezuela-Related Sanctions
• OFAC — Venezuela-Related Sanctions (general licenses, EOs, regulations)
• Congressional Research Service — Venezuela: Overview of U.S. Sanctions Policy (IF10715)

Recent Developments (Oil and Finance)

• Executive Order 14373 — “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People” (January 9, 2026)
• OFAC GENERAL LICENSE NO. 46: Authorizing the Sale of U.S.-Origin Diluents to Venezuela, January 29, 2026
• OFAC GENERAL LICENSE NO. 47: Authorizing the Sale of U.S.-Origin Diluents to Venezuela, February 3, 2026
• OFAC Issuance of New and Amended Venezuela-related General Licenses 48, 46A, 30A, February 10, 2026
• OFAC GENERAL LICENSE NO. 51: Authorizing Certain Activities Involving Venezuelan-Origin Gold, March 6, 2026
• OFAC GENERAL LICENSE NO. 58: Authorizing Certain Services to the Government of Venezuela in Connection with Potential Debt Restructuring

Background Legal Framework (Oil and Finance)

• EO 13692 (March 2015): Declared national emergency with regard to the threat in Venezuela.
• EO 13808 (August 2017): Prohibited Venezuela’s access to U.S. financial markets; blocked purchase of new Venezuelan government debt.
• EO 13835 (May 2018): Prohibited purchase of Venezuelan government debt and equity interests.
• EO 13850 (November 2018): Authorized blocking sanctions on individuals operating in designated sectors of the Venezuelan economy, including oil and gold, or engaging in corruption or material support to the Maduro regime.
• EO 13857 (January 2019): Redefined “Government of Venezuela” to include PDVSA, Central Bank, and related entities.
• EO 13884 (August 2019): Blocked all property of the Government of Venezuela in the U.S. — the most sweeping measure, effectively constituting a comprehensive financial embargo.

PDVSA corporate structure as presented in this securities offering document prior to the court-approved sale of CITGO Petroleum in November 2025. However, the execution of the sale has been put on hold in light of pending regulatory approvals, particularly from the U.S. Treasury.

• NRGI Venezuela country profile