OFAC Expands Venezuela Sanctions Relief: New General Licenses and Updated Guidance

Since issuing General License (GL) 46 on January 29, 2026 (authorizing certain transactions related to Venezuelan-origin oil, as we previously wrote about here), OFAC has continued to ease Venezuela sanctions through new and amended general licenses and updated guidance.

New General Licenses

General License 47 (available here):  Authorizes transactions, including with the government of Venezuela, Petróleos de Venezuela, S.A. (“PdVSA”), and entities owned, directly or indirectly, 50% or more by PdVSA, that are ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, marketing, delivery, or transportation of U.S.-origin diluents to Venezuela, including the processing of payments and shipping and logistics services.  Requires commercially reasonable payment terms and that any contracts with the government of Venezuela, PdVSA, or PdVSA-owned companies contain U.S. choice-of-law and forum selection clauses; does not authorize payments in gold or any digital currency associated with the government of Venezuela, or transactions involving Iran, North Korea, or Cuba; and imposes certain reporting requirements.

General License 48 (available here):  Authorizes transactions, including with the government of Venezuela, PdVSA, and entities owned, directly or indirectly, 50% or more by PdVSA, that are ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, or production of oil or gas in Venezuela, including the processing of payments, shipping and logistics services, and transactions for the maintenance of oil or gas operations in Venezuela.  Same core conditions as GL 47, with additional exclusions for Russia and China, and requires sanctioned-person payments be routed to the Executive Order 14373 U.S. government-controlled account.

General License 49 (available here):  Authorizes transactions, including with the government of Venezuela, PdVSA, and entities owned, directly or indirectly, 50% or more by PdVSA, that are related to the negotiation of and entry into contingent contracts for new investment in oil or gas sector operations in Venezuela, including the development of new operations, the expansion of existing operations, and the formation of joint ventures to pursue the same, provided that the performance of any such contract is made expressly contingent upon separate authorization from OFAC.  “Contingent contract” is 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 does not authorize transactions involving Russia, Iran, North Korea, Cuba, or China.

General License 50A (available here):  Authorizes transactions, including with the government of Venezuela, PdVSA, and entities owned, directly or indirectly, 50% or more by PdVSA, that are related to BP PLC’s, Chevron Corporation’s, Eni S.p.A.’s, Établissements Maurel & Prom SA’s (added in GL 50A), Repsol S.A.’s, or Shell PLC’s oil or gas sector operations in Venezuela.  Same core conditions as GL 48.

Amended General Licenses

General License 5U (available here):  Authorizes all transactions related to, the provision of financing for, and other dealings in PdVSA 2020 8.5 Percent Bond on or after March 20, 2026.  GL 5U further delays the effectiveness of this authorization originally announced in 2019 (see OFAC FAQ #595; available here).

General License 30B (available here):  Authorizes certain transactions related to the operations and use of ports and airports in Venezuela.  GL 30B removes a restriction regarding the exportation of diluents to Venezuela that was in GL 30A (see OFAC FAQ #1236; available here).

General License 46A (available here):  Amends GL 46 to clarify that local taxes, permits, or fees may be paid directly to U.S.-sanctioned persons (including the government of Venezuela) (see also OFAC FAQ #1237; available here).

New Guidance

OFAC has issued new guidance regarding GL 46.  Among other things, the new guidance:

• Confirms that “Venezuelan-origin oil” means crude oil or petroleum products (which is broadly defined) extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products (OFAC FAQ #1226; available here);

• Confirms the broad scope of activities covered by GL 46 (OFAC FAQ #1227; available here) and that GL 46 authorizes downstream trading activities in Venezuelan-origin oil (OFAC FAQ #1235; available here), but clarifies that GL 46 does not authorize new investment activities (OFAC FAQ #1228; available here);

• Defines “commercially reasonable terms” to mean “terms that are consistent with prevailing market and industry standards for like or similar products produced by a company of similar size and scope, while taking into account characteristics such as quality, quantity, pricing, performance, and safety, among others” (OFAC FAQ #1232; available here); and

• Clarifies the authorization for “established U.S. entit[ies]” and the U.S. choice-of-law and forum selection clause requirements (OFAC FAQs #1229-1230 and 1233; available here).