In recent weeks, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has greatly expanded the scope of authorized activities and transactions that U.S. persons may undertake regarding energy projects in Venezuela. The expanded authorizations align with the wider U.S. strategy to relax certain sanctions after President Maduro’s removal on January 3, 2026, signaling a significant shift toward broader commercial engagement with Venezuela’s energy industry.
The series of recent General Licenses (GLs) modify and expand upon prior GLs issued on January 29 and February 3, 2026, creating authorization for a wider range of transactions involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA) and associated entities. At a high level, the newly issued GLs include: broad authorization for all oil and gas transactions for certain identified companies; authorization for the supply of specified goods, services, technology and software for oil and gas exploration, development and production in Venezuela; and authorization for the negotiation and entry into oil and gas investment contracts, contingent upon separate specific licensing by OFAC.
The five GLs are summarized in detail below.
GL 46A – Additional Activities Involving Venezuelan-Origin Oil
GL 46A is an amended version of GL 46 and supersedes GL 46 in its entirety.
At a high level, GL 46 is designed to enable established U.S. energy companies to extract, transport, sell, export and refine Venezuelan-origin oil. GL 46 has several conditions, including a requirement that monetary payments to blocked persons pursuant to this authorization must be made into a Foreign Government Deposit Funds account.
As clarified in OFAC FAQ #1237, GL 46A continues to authorize the payment of routine local taxes, permits and fees to the Government of Venezuela or its instrumentalities, and such payments are not required to be made into a Foreign Government Deposit Funds account.
Despite the broad scope of this authorization, PdVSA reportedly has nevertheless declined to sell oil to companies without specific OFAC licenses. It remains to be seen whether the additional GLs released on February 10 and 13 will change this.
GL 48 – Items and Services Related to the Exploration, Development or Production of Oil or Gas in Venezuela
GL 48 authorizes certain transactions prohibited by the Venezuela Sanctions Regulations (VSR), including those involving the Government of Venezuela or PdVSA that are ordinarily incident and necessary to the provision of goods, technology, software and services from the United States or by a U.S. person for the exploration, development or production of oil or gas in Venezuela.
Unlike GL 46A, this authorization is not restricted solely to “established U.S. entities,” but rather, applies to entities operating from within the United States or U.S. persons. This would include non-U.S. person entities operating within the United States.
While the scope of authorized support activities under GL 48 is similar to GL 46A, the key distinction is that GL 48 does not authorize the sale or purchase of Venezuelan-origin oil. Rather, GL 48 focuses on services and infrastructure support, including maintenance of oil or gas operations, refurbishment or repair of equipment used in exploration, development or production activities, chartering of vessels, marine insurance, port and terminal services, and payment processing related to such authorized activities.
Notably, GL 48 does not authorize the formation of new joint ventures or other entities in Venezuela to explore or produce oil or gas, or any transactions related to the exportation or reexportation of diluents to Venezuela.
GL 49 – Contingent Contracts for Certain Investment in Venezuela
GL 49 authorizes certain transactions prohibited by the VSR, including those involving the Government of Venezuela or PdVSA that are related to the negotiation of and entry into contingent contracts for new investment in oil or gas sector operations in Venezuela.
The GL requires that any contract is expressly contingent upon separate specific authorization from OFAC. Accordingly, any contract established under GL 49 must be additionally authorized through specific engagement with OFAC’s licensing process. The GL confirms that “contingent contracts” are defined to include: executory contracts, executory pro forma invoices, agreements in principle, executory offers capable of acceptance such as bids or proposals in response to public tenders, binding memoranda of understanding, or any other similar agreement.
GL 49 contains similar restrictions to GL 46A, in that it does not authorize transaction involving persons located in Russia, Iran, the Democratic People’s Republic of Korea (DPRK), Cuba, China or entities associated with such persons.
GL 50A – Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities
GL 50A authorizes all transactions prohibited by the VSR, including those involving the Government of Venezuela or PdVSA that are related to oil or gas sector operations in Venezuela of certain specific listed entities. GL 50A supersedes GL 50 in its entirety. The only change in 50A is the addition of one entity to the list.
GL 50A contains similar conditions on payments as GL 46A. Monetary payments to blocked persons, excluding payments for local taxes, permits or fees, as well as oil or gas taxes or royalties paid to the Government of Venezuela, PdVSA and associated entities must be paid into Foreign Government Deposit Funds, or other accounts as instructed by the Treasury Department. Treasury has not issued guidance yet on the mechanics of paying into these funds.
Restrictions on payment types and payment terms remain the same as GL 46A. Restrictions on the involvement of certain foreign persons are the same as those in GL 49, described above.
GL 50A contains a similar reporting requirement as GL 46A and GL 47. Parties transacting pursuant to the GL must send reports to OFAC detailing the nature of the transaction, parties involved and any payments made to the Government of Venezuela.
GL 30B – Certain Transactions Related to Port and Airport Activities
Finally, GL 30B authorizes certain transactions related to operations or use of ports or airports in Venezuela. GL 30B replaces and supersedes GL 30A, which was issued on February 2, 2021, and maintains a largely similar scope of authorization.
Transactions otherwise prohibited by Executive Order 13850 involving the Instituto Nacional de los Espacios Acuaticos (INEA) (Venezuela’s national maritime and waterways authority) and associated entities that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela are authorized under GL 30B.
GL 30B does not authorize any transactions or activities otherwise prohibited by the Venezuela Sanctions Regulations, or with any blocked person other than the INEA and associated entities, or any Government of Venezuela person that is blocked solely pursuant to Executive Order 13884, unless separately authorized by OFAC.
Unlike prior GL 30A, GL 30B no longer contains express exclusion for transactions related to the exportation or reexportation of diluents to Venezuela. Instead, GL 30B relies on the general limitation that it does not authorize transactions otherwise prohibited by the VSR unless separately authorized.
Looking Forward
The GLs released in recent weeks broaden the scope of authorizations applicable to oil-related activities in Venezuela. Given this expanded scope, OFAC may continue to release additional FAQs and interpretive guidance, as well as additional authorizations. As OFAC’s approach to Venezuela continues to evolve, careful transaction structuring and compliance remains essential for parties seeking to operate under GLs.
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