On Thursday, January 29, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Venezuela General License 46 (“GL 46”). GL 46 authorizes transactions previously prohibited by OFAC’s Venezuela Sanctions Regulations—including transactions with or involving the Government of Venezuela (“GoV”), including Petroleos de Venezuela S.A. (“PdVSA”) and its subsidiaries—that are ordinarily incident and necessary to a broad range of activities related to Venezuelan-origin oil, subject to certain limitations and requirements.
- Notably, GL 46 only extends to transactions that are ordinarily incident and necessary to activities undertaken by “established U.S. entities” that were organized under the laws of the United States on or before January 29, 2025.
- Any contract covering authorized transactions with the GoV, PdVSA or its subsidiaries must be expressly governed by U.S. law and subject to dispute resolution in the United States.
- Any payment to a blocked person must be made to the Foreign Government Deposit Funds, as defined in Executive Order 14373 of January 9, 2026, or any other account as directed by the Department of the Treasury.
- Any person that exports, reexports, sells, resells, or supplies Venezuelan-origin oil to countries other than the United States in reliance on GL 46 must report such transactions to the U.S. Department of State and the U.S. Department of Energy.
GL 46 also specifies transactions and activities that are not authorized under its terms, including:
- Payments involving debt swaps and payments in gold or digital currency, coin, or tokens issued by, for, or on behalf, of the GoV.
- Transactions involving Russian, Iranian, North Korean, or Cuban persons or entities owned or controlled by, or in a joint venture with, such persons.
- Transactions involving Venezuelan or U.S. entities owned or controlled by, or in a joint venture with, a Chinese entity.
- Any transaction involving a blocked vessel.
GL 46 represents an important first step by the Trump administration to modify the existing U.S. sanctions framework for Venezuela in order to encourage investment and the recovery of Venezuela, as discussed in S&C’s prior memorandum to clients. The situation remains fluid and further measures are expected over time. S&C is closely tracking developments in this area and is ready to help clients analyze potential transactions involving Venezuela and ensure compliance with applicable sanctions.