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Venezuela - Non-public debt - August 2026

  • Writer: Arbat Capital
    Arbat Capital
  • 16 hours ago
  • 2 min read

Venezuela’s non-bond debt is not a single market, but a collection of arbitral awards, court judgments recognizing those awards, commercial judgments, and settlement obligations.



Venezuela’s non-bond debt is not a single market, but a collection of arbitral awards, court judgments recognizing those awards, commercial judgments, and settlement obligations. Liquidity is low; economic value depends not only on face value, but also on attachment priority, asset availability, sanctions authorizations, and the quality of the chain of assignments.

The best-known example of a judgment concerning such debt is Rusoro Mining Ltd. (a Canadian company), whose principal gold-mining assets were expropriated under the nationalization policy pursued by President Hugo Chávez. In 2018, under the administration of Nicolás Maduro, Venezuela entered into a settlement agreement with Rusoro for more than $1.28 billion and subsequently failed to make the initial payment. The Rusoro debt therefore has three layers of confirmation: an arbitral award, judicial recognition in the United States, and direct contractual acknowledgment by Venezuela.

The Delaware court had approved the sale of shares in PDV Holding, the indirect owner of CITGO, to Amber Energy for approximately $5.9 billion. Closing, however, remains subject to OFAC authorization and ongoing appeals. Approval of the sale is therefore not equivalent to payment having already been made to creditors.

The strongest category of claims “recognized by the Venezuelan authorities” consists of debts for which Venezuela or PDVSA itself entered into a payment agreement: Rusoro, Crystallex, Gold Reserve, and ConocoPhillips’ separate commercial claim against PDVSA. The arbitral awards in favor of OI European Group, Koch, Tidewater, Valores Mundiales/Consorcio Andino, Vestey, Air Canada, and others have been legally established, but were not necessarily acknowledged by the Venezuelan authorities through separate settlement agreements.

The market discount cannot be determined precisely, although there are reports of debt sales at 25–30% of face value. A publicly confirmed benchmark exists, for example, for O-I: $115 million for the right to proceeds from an arbitral award sold in 2017.

The mere existence of an award or court judgment does not ensure recovery. Critical factors include the finality of the decision, recognition in the target jurisdiction, the availability of commercial assets, immunity, the alter-ego relationship between Venezuela and PDVSA, sanctions, and position in the priority queue.

The “Delaware queue” is not a complete register of all Venezuelan debt. It covers creditors that obtained specific procedural rights against the PDVH shares or were admitted to the proceeding.

Not all these creditors occupy the same procedural position. Air Canada and Vestey hold awards but do not appear on the published list of attached judgment creditors in the CITGO proceeding; Favianca/Owens-Illinois de Venezuela lost the underlying jurisdictional dispute; and García Armas has a complicated annulment history and should not be described as a simple, undisputed $49 million debt.



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