1. OFAC (Office of Foreign Assets Control)

This body holds all cases filed across the various U.S. courts, including the challenges to the Citgo sale process led by Judge Stark and Special Master Pincus. It also addresses PDVSA Ad Hoc Board’s omission regarding workers under the Alter Ego doctrine.

Pending Management Review & Active Actions: Our specific license petition (Case ID: VENEZUELA-EO13850-2025-1395693-1, filed September 2025) is under active management review. Today we filed a formal supplement attaching the newly docketed Delaware motions (Stark Doc. 2658 and Hall Doc. 72), OFAC General Licenses 52 and 5V (March 18–19, 2026), and the UN Human Rights Council statement (Volker Türk, March 16, 2026). GL 52 directs PDVSA revenues into Treasury-controlled Foreign Government Deposit Funds, while GL 5V extends protection for the 2020 8.5% bondholders until May 5, 2026.

What we are doing to ensure QSF: We are explicitly requesting a specific license allocating 5% of the Foreign Government Deposit Funds (generated under GL 52) to a court-supervised Qualified Settlement Fund for the 23,000 purge survivors. This creates a direct, safeguarded revenue mechanism that complements the Citgo sale without disruption.

2. Delaware Court (Judge Stark – Case 1:17-mc-00151-LPS)

Selection of Amber as trustee / Citgo auction: Amber Energy (affiliated with Elliott) submitted a bid for Citgo’s parent company (PDV Holding) of approximately US$ 5.9 billion, with a collateral agreement to pay US$ 2.1 billion to the holders of the PDVSA 2020 bonds.

Major Breakthrough: The Court has formally docketed our Emergency Motion to Lift the Docket Access Restriction (previously vetoed) as Document 2658 (March 17, 2026).

What we are doing to ensure QSF: Today we filed a supplement to Doc. 2658 highlighting the dual docketing with the Hall case (Doc. 72), the new OFAC GLs 52 and 5V (which protect bondholders while generating Treasury funds), and the equity argument that commercial creditors cannot receive sanctions relief while victims are excluded. We are requesting expedited briefing, partial veto lift, and a decree establishing the Qualified Settlement Fund with a proposed 5% set-aside from the same safeguarded revenues. Dr. Garrett appeared in court on October 20, 2025; the process is now accelerating.

3. Court Judge Hall (Case 1:24-cv-00380-JLH)

Review of the case requesting acceptance of natural creditors under the Alter Ego doctrine.

Major Breakthrough: The Court has formally docketed our Motion for Joinder/Substitution of the Delcy Rodríguez government as Document 72 (March 17, 2026).

What we are doing to ensure QSF: Today we filed a supplement to Doc. 72 tying the joinder request to the Stark motion (Doc. 2658), the new OFAC GLs 52 and 5V (which accommodate bondholders while creating Treasury funds), and the need to certify QSF issues to Judge Stark. We are requesting joinder of the recognized government and expedited coordination for a 5% victim set-aside, ensuring commercial debt does not displace human-rights claims.

4. Court of Appeals (Third Circuit – Lead Case 25-3347 and related appeals)

Motions submitted questioning malpractice by both Judge Stark and Special Master Pincus, including lack of transparency and crossed-out documents.

Updated Status: Multiple supplements have been filed under FRAP 28(j).

What we are doing to ensure QSF: Today we filed a new FRAP 28(j) supplement highlighting the dual Delaware docketing (Stark Doc. 2658 + Hall Doc. 72) and the new OFAC GLs 52 and 5V (which protect bondholders while generating Treasury funds). We are urging remand for equitable QSF allocation, arguing that sanctions relief to commercial creditors requires parallel relief for victims under the alter ego doctrine (Crystallex, 932 F.3d 126).

5. IACHR (Inter-American Commission on Human Rights)

Registration of the case of the 23,000 survivors of the PDVSA purge in Venezuela (File: MC-1393-25).

Updated Status: Recent supplements incorporate dual Delaware docketing and the new OFAC licenses.

What we are doing to ensure QSF: Today we filed a supplemental update attaching the docketed motions (Stark Doc. 2658 + Hall Doc. 72), OFAC GLs 52 and 5V (creating revenue streams for reparations), and the UN Human Rights Council statement (Volker Türk, March 16, 2026). We are urging expedited precautionary measures to guarantee victim inclusion in the Qualified Settlement Fund during the U.S.-led transition process.