Venezuela Sanctions Update: Tracking OFAC General Licenses Post-Maduro

In recent months, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued a significant series of new and updated general licenses (“GLs”) reshaping the compliance landscape for companies seeking to engage in Venezuela’s energy and minerals sectors. Taken together, these actions represent an opening of sectors that had been substantially closed to U.S. persons under the Venezuela sanctions program for several years. Building on our prior alert, this alert summarizes the relevant GLs and sets out practical considerations for companies evaluating whether and how to proceed. See the table at the end of this alert summarizing the various GLs in place.

Background: Venezuela Sanctions Framework

The core U.S. sanctions against Venezuela have been in place for more than a decade, starting when Congress passed the Venezuela Defense of Human Rights and Civil Society Act, implemented through Executive Order (“EO”) 13692, which established the first country-specific program aimed at Venezuela. The first Trump Administration expanded U.S. sanctions, imposing, among other actions, debt-related restrictions on Petróleos de Venezuela, S.A. (“PdVSA”)—Venezuela’s state-owned oil company—along with the Government of Venezuela (“GoV”). Later, in 2019, as part of President Trump’s “maximum pressure” effort, OFAC designated PdVSA on the List of Specially Designated Nationals and Blocked Persons (“SDN List”) and then “blocked” the GoV, subjecting PdVSA, the GoV, and all Venezuelan state-owned entities to a U.S. asset freeze, cutting them from all transactions and dealings with U.S. persons, and creating significant secondary sanctions risk for non-U.S. persons if they engaged with any of these entities. In particular, this gave rise to significant restrictions on dealings with Venezuela’s oil and gas industry.

Following the January 3, 2026, U.S. military operation in Caracas that resulted in the capture of Venezuelan President Nicolás Maduro and his transfer to the United States to face federal criminal charges, OFAC has significantly eased Venezuela-related sanctions. Specifically, OFAC has issued certain GLs to promote trade and investment relating to Venezuela’s oil, gas, and minerals industries, as detailed below. 

This update reviews the current state of Venezuela sanctions as the United States seeks to strike a balance between encouraging the GoV while ensuring that Venezuela does not backslide into activity contrary to U.S. policy. The use of these GLs affords OFAC the flexibility to quickly snap back sanctions if U.S. policymakers determine that Venezuela has not made sufficient progress on key market-opening and human rights reforms. 

General License 46 / 46A / 46B — Venezuelan Oil and Petrochemical Exports

First published on January 29, 2026, and revised twice thereafter—on February 10, 2026 (as GL 46A) and March 13, 2026 (as GL 46B)— this general license permits an array of transactions tied to exporting Venezuelan-origin oil and importing petrochemical goods into the United States, each to be carried out exclusively by “established U.S. entities.”

The license defines an “established U.S. entity” as “any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.”  

The authorization under GL 46B covers crude oil, crude oil blends, and petroleum products within the meaning of FAQ 1226, along with petrochemical products as separately defined in the license text. Importantly, GL 46B’s reach does not extend to natural gas or to energy-related activities more broadly. GL 46B excludes any transaction that uses non-commercial or abnormal payment terms, such as debt swaps, gold payments, or digital currency issued by the Venezuelan government. The license also bars transactions involving Russia, Iran, North Korea, Cuba, or entities they own, control, or partner with, including certain Chinese-linked entities operating in Venezuela or the United States.

General License 47 — Sale of U.S.-Origin Diluents to Venezuela

Published on February 3, 2026, GL 47 permits transactions relating to the sale and delivery of diluents produced in the United States to Venezuelan buyers. GL 47 excludes transactions with persons or entities from Iran, North Korea, Cuba, and blocked vessels, but unlike other general licenses, does not exclude Russia or China. Parties must still screen all counterparties and confirm which license applies due to these exclusions.

General License 48 / 48A — Goods, Technology, and Services for Venezuelan Energy Operations

GL 48A (issued on March 13, 2026, and superseding GL 48 of February 10, 2026) permits U.S. persons and persons operating from the United States to supply goods, technology, software, and services supporting the exploration, extraction, or production of oil, gas, and petrochemical products in Venezuela, as well as activities related to Venezuelan electricity generation, transmission, storage, and distribution. GL 48A contains express prohibitions on establishing new joint ventures or corporate entities within Venezuela and on exporting or re-exporting diluents to the country. Furthermore, persons engaging in activity authorized under GL 48A still must comply with any applicable restrictions under the U.S. Export Administration Regulations (“EAR”).

General License 49 / 49A — Contingent Contracts for New Investment

GL 49A (issued on March 13, 2026, and superseding GL 49 of February 13, 2026) authorizes the negotiation, drafting, and execution of contingent contracts contemplating new investment across Venezuela’s oil, gas, petrochemical, and electricity sectors. The activity is permitted only if the final contract explicitly requires obtaining an OFAC license before performing the agreement. Notably, this authorization is not limited to “established U.S. entities” as certain other GLs are.

General Licenses 50 / 50A — Named Energy Companies

GL 50A, aimed at spurring international investment in Venezuela’s oil and gas sectors, (issued on February 18, 2026 and superseding GL 50 of February 13, 2026) authorizes certain specified prominent energy companies and their corporate subsidiaries to conduct oil and gas operations within Venezuela.

General License 52 – Authorizing Certain Transactions Involving PdVSA

GL 52, issued March 18, 2026, more fully removes sanctions relating to transactions with PdVSA, authorizing an “established U.S. entity” (as defined above in earlier GLs) to engage in all transactions prohibited by EO 13884 (authorizing the imposition of asset-freezing sanctions on PdVSA) or EO 13850 (authorizing the imposition of asset-freezing sanctions on the GoV), if those transactions involve PdVSA, or any entity PdVSA owns 50 percent or greater.

FAQ 1245 explains that transactions authorized by GL 52 include activities related to:

• the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan oil or petroleum products of Venezuelan-origin oil and petroleum products;

• the provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors;

• entry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products sectors of Venezuela;

• the formation of new joint ventures or other entities in Venezuela related to such activities; and

• all transactions ordinarily incident and necessary to such activities, including the performance of commercial, legal, technical, safety, and environmental due diligence and assessments related to the foregoing.

General Licenses 51 / 51A, 54 and 55 – Minerals Transactions

OFAC has issued three GLs authorizing a range of transactions involving Venezuela’s minerals sector.

• GL 51A (issued March 27, 2026 and superseding GL 51 of March 6, 2026) authorizes “established” U.S. entities to engage in certain transactions with the GoV, CVG Compania General de Mineria de Venezuela CA (“Minerven”), or entities owned 50percent or greater by Minerven, involving the exportation, reexportation, sale, purchase, delivery, and transportation of Venezuelan-origin minerals, including gold. The GL requires that relevant contracts are governed by U.S. law and that monetary payments to blocked persons are deposited into the Foreign Government Deposit Funds or other U.S. Treasury-designated accounts. Notably, the GL excludes transactions involving persons or entities located or organized in Russia, Iran, North Korea, or Cuba, or Chinese-owned or controlled U.S. or Venezelan entities. Since the GL does not authorize mining or extraction activities within Venezuela, its impact was limited to allowing existing Venezuelan entities to sell these critical minerals, rather than developing new sources. As a result, OFAC issues additional GLs to address these activities.   

• Published on March 27, 2026, GL 54 authorizes certain transactions involving U.S.-origin goods, technology, software, or services for minerals operations, including the exploration, reexportation, sale, and production of minerals such as gold in Venezuela.

• GL 55, issued on March 27, 2026, permits transactions related to negotiating and entering into certain conditional contracts for new investments in Venezuela’s mineral industry, including the gold sector. This is similar to GL 49A summarized above, and like GL 49A, is not limited to established U.S. entities. 

• By separating investment, exploration, and extraction from sales activity, the GLs create the possibility of a staged snapback if the Trump Administration’s goals are not met.

General License 56 – Negotiation of Contingent Contracts

Continuing the rollback of sanctions, on April 14, 2026, OFAC released GL 56, which authorizes all transactions prohibited by EO 13884 that are ordinarily incident and necessary to engage in commercial-related negotiations of contingent contracts with the GoV, provided that the entry into any such contract is separately authorized by OFAC. However, GL 56 does not authorize transactions otherwise prohibited by the Venezuela Sanctions Regulations (“VSR”), such as transactions prohibited by EO 13808 or EO 13835. The license also does not permit non-commercially reasonable payment terms, transactions involving persons or entities from Russia, Iran, North Korea, Cuba, or Chinese-owned or-controlled entities, enforcement of liens or judgments against blocked property, or dealings with individuals or entities on OFAC’s SDN List.

General License 57 – Authorizing Certain Financial Services Transactions

Published on April 14, 2026, GL 57 authorizes all transactions prohibited by the VSR that are ordinarily incident and necessary to the provision, exportation, or reexportation of financial services to, from or for the benefit of the following entities and individuals: Banco Central de Venezuela; Banco de Venezuela; Banco Digital de los Trabajadores Banco Universal C.A.; Banco del Tesoro; any entity that is owned by 50 percent or more by those banks; and any individual blocked solely under EO 13884 as part of the GoV as defined in the EO, except for individuals identified on OFAC’s SDN List. GL 57 does not authorize the unblocking of any property blocked pursuant to any part of the VSR chapter V, or any other transactions otherwise prohibited by the VSR, unless separately authorized.

General License 58 – Authorizing Certain Services in connection with Potential Debt Restructuring

Released on May 5, 2026, GL 58 permits transactions that are ordinarily incident and necessary to the provision of legal, financial advisory, and consulting services to the GoV, PdVSA, or any entity PdVSA owns 50 percent or greater, in connection with potential restructuring of debt of the GoV, PdVSA, or its related entities. Services and transactions that are authorized by this license include the assessment, development, or preparation of debt restructuring options, proposals, and related supporting materials. GL 58 does not, however, authorize the actual restructuring, transfer, or settlement of debt of the GoV, including the debt of PdVSA and PdVSA related entities, or direct negotiations between the GoV, PdVSA and its entities, and creditors.

Other Key Conditions Applicable Across the General Licenses

U.S. Law and Dispute Resolution Requirements

GLs 46B, 47, 48A, 50A, 51, and 52 mandate that any agreement governing the licensed activity be subject to U.S. law and include provisions directing dispute resolution to forums within the United States. OFAC has confirmed through FAQ 1233 that the dispute resolution mandate pertains exclusively to contracts between established U.S. entities and sanctioned Venezuelan counterparties; it does not extend to agreements with non-sanctioned third parties.

Foreign Adversary Exclusions

GLs 46B through 51 bar transactions that involve sanctioned vessels or parties with specified ties to Russia, Iran, North Korea, or Cuba. A subset of these licenses—GLs 48A through 50A—extends the exclusion to entities connected to China as well. GLs 46B and 51 also exclude U.S. and Venezuelan entities that are owned or controlled by, or are participants in joint ventures with, Chinese persons. By contrast, GL 47 does not incorporate the Russia- or China-related exclusions.

Mandatory Payment Controls

GLs 46B, 48A, 50A, 51, and 52 stipulate that all payments owed to blocked persons—with the exception of local taxes, permits, and fees—must be routed into designated Foreign Government Deposit Funds or other accounts identified by OFAC. The proceeds held in these accounts are administered by the U.S. government for the benefit of the GoV.

Ability of Non-U.S. Persons to Operate Under Certain General Licenses

FAQ 1247 clarifies that non-U.S. persons do not face sanctions risk for engaging in transactions authorized by GLs 46B, 51A, and 52, provided that the non-U.S. person comply with the following conditions:

• The non-U.S. entity is organized under a third country’s laws on or before January 29, 2025, (thus reducing the likelihood that bad actors will create companies to attempt to exploit these opportunities);

• Payments to blocked persons (other than local taxes, permits, or fees) are deposited into the Foreign Government Deposit Funds pursuant EO 14373, or another Treasury-designated account;

• Payment terms are commercially reasonable;

• Payment terms do not involve debt swaps or Venezuelan government-issued digital currency (including the petro);

• The transaction does not involve any person or entity located in, organized under, or in a joint venture with persons from Russia, Iran, North Korea, or Cuba;

• The transaction does not involve any Venezuelan or U.S. entity owned, controlled by, or in a joint venture with a Chinese person or entity;

• The transaction does not involve a blocked vessel; and

• For GL 51A transactions, Venezuelan-origin minerals (including gold) are not processed or refined in Russia, Iran, North Korea, Cuba, or China.

Reporting Obligations

GLs 46B, 47, 48A, 50A, and 51 each impose obligations to make certain filings with OFAC. Under GL 46B, reporting is triggered when Venezuelan-origin oil is sold to buyers outside the United States; the first report must be filed within 10 days of the initial qualifying sale, with follow-up reports at 90-day intervals. These submissions must detail the transacting parties, the volumes and monetary values of the goods traded, and the relevant transaction dates. GL 46B further demands identification of the final destination countries for exported oil, while GL 51 requires companies to submit documentation outlining their supply chain due diligence frameworks.

Compliance Considerations

Companies relying on the Venezuela GLs should keep in mind several key compliance points:

• Each transaction requires its own careful review, as license terms and counterparty restrictions vary, and a single deal may rely on multiple licenses.
• Counterparty diligence is crucial, as foreign adversary exclusions differ across licenses and require careful vetting of ownership and control.
• Export control rules under the EAR still apply, so companies must assess whether their activities with Venezuela trigger additional licensing or restrictions, especially when sensitive parties are involved.
• Ongoing monitoring is essential, as OFAC frequently updates guidance and revises licenses, requiring compliance teams to stay informed of all sanctions program changes.

Summary of General Licenses:

For more information or assistance, please contact Anthony Rapa, Kenneth J. Nunnenkamp, Ekinsu Cebi Elkei, Feven T. Negussie, or another member of Blank Rome’s International Trade practice group.