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Overview
On January 29, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued Venezuela-related General License 46 ("GL 46"), "Authorizing Certain Activities Involving Venezuelan-Origin Oil". GL 46 establishes a new authorization regime for established U.S. entities engaging in a defined set of activities involving Venezuelan-origin oil that would otherwise be prohibited by the Venezuela Sanctions Regulations, 31 CFR Part 591.
In a significant departure from the more restrictive posture the Trump Administration previously adopted toward Venezuela's oil sector, notably marked by aggressive sanctions enforcement and several high-profile vessel seizures, the United States has now taken a materially different approach post detention of Nicolás Maduro. We previously discussed sanctions actions and recent developments in the Venezuelan oil and gas space on January 6, 2025. Against this backdrop, the issuance of GL 46 represents a meaningful pivot with a broader authorization framework that eases sanctions pressure on the region. We note that licensing in this area continues to rapidly develop, and reports indicate additional general licenses and specific licenses may be issued.1
Scope and Conditions of Authorized Activities
Under GL 46, an established U.S. entity may conduct transactions ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, including the refining of such oil, even when such transactions involve the Government of Venezuela, Petróleos de Venezuela, S.A. ("PdVSA"), or entities in which PdVSA owns, directly or indirectly, a fifty percent or greater interest. These transactions are authorized only if two conditions are satisfied. First, any contract with the Government of Venezuela, PdVSA, or PdVSA-owned entities must specify that U.S. law governs the contract and that any dispute resolution occurs in the United States. Second, any monetary payment owed to a blocked person must be deposited into the Foreign Government Deposit Funds account, as specified in Executive Order 14373 or any successor account designated by the U.S. Department of the Treasury.
The authorization also encompasses shipping and logistics arrangements, including chartering vessels, obtaining marine insurance and protection and indemnity coverage, and arranging port and terminal services, including those provided by Venezuelan government port authorities or terminal operators. It further includes commercially reasonable swaps of crude oil, diluents, or refined petroleum products. An "established U.S. entity" for purposes of GL 46 is defined as an entity organized under the laws of the United States or any U.S. jurisdiction on or before January 29, 2025.
Limitations and Prohibitions
GL 46 contains clear limitations. It does not authorize payment terms that are not commercially reasonable, nor does it allow debt swaps, payments in gold, or payments denominated in any digital currency, coin, or token issued by, for, or on behalf of the Government of Venezuela. It also does not authorize any transaction involving a person located in or organized under the laws of Russia, Iran, North Korea, or Cuba, or any entity owned or controlled by, or in a joint venture with, such persons. In addition, it prohibits transactions involving any entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of China. GL 46 further makes clear that it does not authorize the unblocking of any property or any transaction involving a blocked vessel.
Key Takeaways
GL 46 provides a comprehensive framework for established U.S. entities (as defined above) seeking to reenter or expand their presence in Venezuela's reopened oil sector. It offers a clearer pathway for companies to structure compliant transactions involving Venezuelan-origin oil while still imposing firm guardrails on counterparties, payment structures, and export reporting. Given the rapidly shifting operational environment in Venezuela post-Maduro detention and the broader recalibration of U.S. policy, further measures and additional OFAC guidance appear likely.
We emphasize that the situation remains dynamic, and additional licensing continues to be released concerning the U.S. Venezuela sanctions programs, as seen by the recently issued General License 5U. General License 5U authorizes, on or after March 20, 2026, all transactions related to, the provision of financing for, and other dealings in the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond that would otherwise be prohibited by subsection 1(a)(iii) of Executive Order 13835, as amended, and incorporated into the Venezuela Sanctions Regulations. We will continue to post updates as additional licensing emerges and update this post in the event of further amendments.
Footnote
1 See US lifts some Venezuela sanctions to ease oil sales | Reuters; Treasury opens Venezuelan crude oil trading up to more companies | POLITICO.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
