Key Takeaways
- GL 5W is brand new. OFAC issued it on May 4, 2026 — barely a month ago as of this writing — and it became effective June 19, 2026. It addresses one specific instrument: the PdVSA 2020 8.5% bond.
- GL 9H is the foundational authorization. Issued October 18, 2023, it covers secondary market trading in qualifying Venezuelan securities (sovereign bonds, pre-Executive Order PDVSA bonds, certain equities) across the board.
- GL 5W supplements GL 9H for the 2020 bond. GL 9H is the general framework; GL 5W carves out a specific compliance pathway for bondholders who need to act on the CITGO Holding collateral backing the 2020 instrument.
- The CITGO link is the key distinction. The PdVSA 2020 bond is collateralized by a 50.1% pledge of CITGO Holding shares. GL 5W directly authorizes transactions related to that collateral on or after June 19, 2026 — GL 9H alone does not address this specifically.
- Neither license authorizes transactions with SDN-listed parties. Counterparty screening remains mandatory regardless of which general license applies.
Contents
Compliance officers working Venezuela debt portfolios are asking the same question in mid-2026: does OFAC General License 5W vs 9H matter for my specific holdings? The short answer is yes — but which one matters depends entirely on whether you hold the PdVSA 2020 8.5% bond and whether your activity touches the CITGO Holding collateral. This guide maps the scope, dates, and limits of each license so you can route your activity to the right authorization before you act.
Side-by-Side Comparison
Here is the quick comparison of OFAC GL 5W vs GL 9H across the seven dimensions that matter most to debt market participants and compliance teams.
| Dimension | General License 5W | General License 9H |
|---|---|---|
| Covered instrument | PdVSA 2020 8.5% bond only (collateral = 50.1% of CITGO Holding shares) | Venezuelan securities issued before specified Executive Orders (sovereign bonds, PDVSA bonds pre-EO, certain equities) |
| Effective date | June 19, 2026 (issued May 4, 2026) | October 18, 2023 |
| Who can use it | Bondholders of the PdVSA 2020 8.5% bond | Any secondary market participant in qualifying Venezuelan securities |
| Authorized activities | Transactions related to the bond's collateral on or after June 19, 2026 | Secondary market trading in qualifying Venezuelan securities |
| CITGO relevance | Directly relevant — the PdVSA 2020 bond is collateralized by 50.1% of CITGO Holding shares; GL 5W specifically addresses collateral-related transactions | Indirect — covers PDVSA debt broadly but does not specifically address 2020 bond collateral enforcement |
| Relationship to other GLs | Supplements GL 9H for the specific 2020 bond; supersedes GL 5T | Foundational authorization for all qualifying Venezuelan debt secondary trading; supersedes GL 9G |
| Current status (2026) | Active (issued May 2026, effective June 19, 2026) | Active (issued October 2023) |
Sources: OFAC Recent Actions (May 2026 — GL 5W) · OFAC Venezuela-Related Sanctions (GL 9H)
What GL 5W Authorizes
OFAC issued General License 5W on May 4, 2026, making it one of the most recent additions to the Venezuela sanctions framework at the time of this writing. Its full title: "Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After June 19, 2026." The effective date — June 19, 2026 — is not the issue date. It is the activation date for the transactions GL 5W permits.
The license is purpose-built for a single instrument. The PdVSA 2020 8.5% bond is backed by a 50.1% pledge of CITGO Holding shares. That collateral structure has hung over the CITGO and Venezuela situation for years, creating uncertainty about what bondholders could legally do when the collateral enforcement question reached a decision point. GL 5W resolves part of that uncertainty by giving bondholders a compliance pathway for collateral-related transactions on or after June 19, 2026.
Compliance officers should note what GL 5W replaced. It supersedes GL 5T, meaning any reliance on GL 5T for the 2020 bond should be re-examined against the new text of GL 5W. If your legal team had mapped out a transaction structure under GL 5T, that analysis needs to be refreshed.
From a portfolio management perspective, GL 5W is described by sanctions practitioners as critical for Venezuelan sovereign-debt holders because it keeps the CITGO collateral question alive without forcing immediate enforcement. Rather than leaving bondholders in a binary situation — either triggering a collateral dispute or doing nothing — GL 5W creates authorized space for collateral-related transactions under defined conditions.
What GL 5W does not do is equally important. It does not override SDN list obligations. Any party involved in the transaction chain — including PDVSA affiliates, CITGO entities, or Venezuelan government-linked counterparties — must be screened against the current SDN list. GL 5W is a general license, not a blanket waiver. For counterparty checks, use the Venezuela sanctions checker as a first-pass filter before bringing in counsel.
What GL 9H Authorizes
General License 9H is the foundational authorization for distressed-debt secondary trading in Venezuelan securities. OFAC issued it on October 18, 2023. It superseded GL 9G and remains active as of mid-2026. Any fund or trader working legacy Venezuelan paper should treat GL 9H as essential reading before any transaction — it is the base layer of the secondary market framework.
The scope is considerably broader than GL 5W. GL 9H covers transactions in certain Venezuelan securities — both debt and equity — that were issued prior to the dates specified in the relevant Executive Orders imposing Venezuela-related sanctions. This means secondary market trading in qualifying sovereign bonds, qualifying PDVSA bonds issued before those Executive Orders, and certain Venezuelan equity instruments can fall within GL 9H's authorization, subject to the conditions it specifies.
The word "secondary" is load-bearing in GL 9H's framework. The license is structured around secondary market activity — buying and selling existing instruments, not issuing new ones or extending new credit to sanctioned Venezuelan entities. Participants who try to stretch GL 9H to cover primary issuance activity or new financing structures will find the authorization does not reach that far.
GL 9H is the reason the Venezuelan Venezuela bonds restructuring landscape has a functioning secondary market at all. Without it, U.S. persons would face a near-total prohibition on transacting in legacy Venezuelan paper. The license has allowed distressed-debt funds to build and trade positions, price Venezuelan risk, and maintain liquidity in instruments that would otherwise be untradeable by U.S. persons.
One important structural point: GL 9H does not solve everything. It is the general framework, but it has conditions. Counterparty screening against the SDN list is mandatory. Transactions that involve SDN-listed parties — even if the underlying security qualifies under GL 9H — are not covered. For a full list of authorized Venezuela general licenses and their conditions, see the OFAC Venezuela General Licenses tool.
Source: OFAC Venezuela-Related Sanctions — GL 9H (October 18, 2023)
The Overlap — When You Need Both
Understanding when GL 5W and GL 9H work together — rather than treating them as alternatives — is the practical compliance question for Venezuela debt holders in 2026. Here is the framework.
GL 5W is relevant if…
- You hold the PdVSA 2020 8.5% bond specifically.
- Your activity involves the CITGO Holding collateral backing that bond.
- You plan to take any action related to the bond on or after June 19, 2026.
- You were previously relying on GL 5T — that analysis must be updated to GL 5W.
GL 9H is relevant if…
- You trade, buy, or sell qualifying Venezuelan securities in the secondary market.
- Your holdings include legacy sovereign bonds or pre-Executive Order PDVSA bonds.
- You need the foundational authorization for any Venezuelan-paper secondary market activity.
- You hold Venezuelan equity instruments issued before the relevant Executive Orders.
For a holder of the PdVSA 2020 8.5% bond who wants to trade the bond position in the secondary market and potentially take action on the CITGO collateral, both licenses are relevant. GL 9H covers the secondary market trading activity; GL 5W covers the collateral-related transactions on or after June 19, 2026. They are not redundant — they address different legal questions for the same instrument.
For any other Venezuela debt participant who does not hold the 2020 bond, GL 9H is likely the primary authorization. GL 5W simply does not apply to instruments other than the PdVSA 2020 8.5% bond.
A practical compliance sequence: first confirm your instrument qualifies under GL 9H (was it issued before the specified Executive Order cutoffs?). Then determine whether your planned activity includes anything touching the PdVSA 2020 bond's CITGO collateral — if so, layer in GL 5W and confirm the June 19, 2026 effective date has passed. Then screen all counterparties against the current SDN list regardless of which license applies. Finally, verify the specific conditions of each license in the current OFAC text, not a secondary summary.
For deeper tracking of how these licenses interact with Venezuela's restructuring outlook, see the Venezuela bonds restructuring guide and our Venezuela Sanctions Tracker. For a comparison with other OFAC Venezuela licenses, see OFAC General License 41 vs 46. Need a documented compliance read for a specific position or counterparty? Our team builds tailored sanctions dossiers that map your holdings to the current OFAC text.