Evolving Venezuela Sanctions: 2026 Executive Actions and General Licenses Redefine Compliance Landscape

This alert was prepared by members of Womble Bond Dickinson's Venezuelan Task Force. Team members include Jose Luis Vittor, Francisco Balduzzi, Alan Enslen, Julius Bodie, and Alex de Gramont. We will be following developments closely and providing regular updates.

The United States has imposed an evolving regime of economic sanctions regulations on Venezuela since 2015, including both targeted and sectoral sanctions administered by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) pursuant to the Venezuela Sanctions Regulations (“VSR”) at 31 CFR Part 591.  However, since the removal of Venezuelan President Nicolás Maduro on January 3, 2026, the Trump Administration has taken several actions to expand Venezuela-related oil trade and investment opportunities previously prohibited by the VSR, including via the following OFAC general licenses authorizing energy sector sanctions relief:

• General License 46 and 46A, authorizing “established U.S. entities” to engage in certain oil export and trade transactions involving the Government of Venezuela, Petróleos de Venezuela, S.A. (“PdVSA”) and associated entities;[1]
• General License 47, authorizing the sale of U.S.-origin diluents to Venezuela;[2]
• General License 48, authorizing U.S. persons to provide goods, technology, software, or services for the exploration, development, or production of oil or gas in Venezuela;[3]
• General License 49, authorizing negotiations of and entry into contingent contracts for new investment in oil or gas sector operations in Venezuela;[4] and
• General License 50, authorizing oil or gas sector transactions with specific Venezuelan entities.[5]

As the U.S. continues to roll out sanctions relief on Venezuela’s energy sector, companies seeking to take advantage of these OFAC general licenses must be aware of their scope and associated limits, along with related compliance obligations - as the framework of OFAC’s VSR program still stands, and numerous individuals and entities in the region are still subject to a wide array of targeted sanctions.

Evolution of OFAC Venezuela Sanctions Regulations

OFAC’s VSR program generally dates back to Executive Order (“EO”) 13692 issued in 2015 by President Obama, which authorized OFAC to impose list-based sanctions (e.g., via the Specially Designated Nationals and Blocked Persons List (“SDN List”)) on individuals and entities determined to be involved in undermining democratic processes, human rights abuses, and public corruption in Venezuela. In 2017, President Trump issued additional EOs targeting then-President Maduro’s government as well as Venezuela’s state-owned oil company PdVSA.  In 2019, PdVSA was designated on the OFAC SDN List, and EO 13884 was issued blocking all property of the Government of Venezuela. 

OFAC does have the authority to issue both General Licenses (which statutorily authorize otherwise prohibited activities in a sanctioned region or with sanctioned parties and without a U.S. company needing to obtain additional written approval from OFAC) as well as Specific Licenses (which come in the form of written approval issued by OFAC in response to a license application). However, outside of the limited authorizations issued by OFAC in the VSR in the form of General Licenses, typically U.S. persons have been required to obtain an OFAC Specific License to deal directly or indirectly with any Venezuelan government official or entity, regardless of whether they are on the SDN List.

In 2022, the Biden Administration pared back certain OFAC VSR sanctions, including by issuing a General License to allow Chevron to resume oil production and engage in certain transactions through its joint ventures with PdVSA. In 2023 and 2024, additional OFAC General Licenses were issued more broadly authorizing certain oil and gas sector transactions in Venezuela that would otherwise be prohibited under the VSR. However, those General Licenses were subsequently revoked by OFAC or were otherwise declined to be renewed. 

2026 OFAC VSR Developments

Following the capture of former Venezuelan President Maduro on January 3, 2026, on January 9 President Trump issued EO 14373 (“Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People”) to protect certain Venezuelan oil-related revenues from attachment or other judicial processes.[6] Specifically, EO 14373 imposes protections applicable to “Foreign Government Deposit Funds” held in U.S. Treasury accounts that are derived from the sale of natural resources from, or the sale of diluents to, the Government of Venezuela or its agencies or instrumentalities (e.g., the Central Bank of Venezuela and PdVSA) - and states that such covered funds are to be the sovereign property of Venezuela held by the United States in a governmental custodial capacity (in effect creating a legal shield around these assets, and preventing private claims by judgment creditors of Venezuela). 

Most recently, OFAC has issued five General Licenses (“GLs”) in a span of 15 days which authorize certain transactions previously prohibited under the VSR relating to Venezuela-origin oil and petroleum products and new investment in Venezuela’s energy sector. 

First, on January 29, 2026, OFAC issued GL 46 authorizing “established U.S. entities” to engage in certain transactions involving the Government of Venezuela, PdVSA and associated entities that are “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.”  OFAC subsequently issued GL 46A on February 10, 2026, with minor changes to the original GL authorizing certain payments for local taxes, permits, or fees.

GL 46 defines “established U.S. entity” as an entity organized under U.S. law on or before January 29, 2025. However, such an entity cannot be owned or controlled, directly or indirectly, (i) by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China, or (ii) by a person located in or organized under the laws of Russia, Iran, North Korea, or Cuba. The text of the GL indicates that transactions must be carried out by the U.S. entity and not by any non-U.S. affiliate.

Further, “Venezuelan oil” includes crude oil as well as other petroleum products, which are defined to include “unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas, and miscellaneous products obtained from the processing of crude oil (including lease condensate), natural gas, and other hydrocarbon compounds.”[7]

Certain support services are also authorized under GL 46, including services related to arranging logistics, security services, shipping, marine insurance, and arranging port and terminal services. OFAC has stated that downstream trading activities (e.g., refining and resale of Venezuelan-origin oil), coordinating payment structures, and financing related cargos or receivables are also covered by GL 46.[8]

GL 46 does not authorize transactions that are not on commercially reasonable terms; payment in gold or the use of debt swaps; payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro; the unblocking of any property blocked pursuant to the VSR; or any transaction involving a blocked vessel. GL 46 also imposes strict conditions on payments made pursuant to its authorization, and any payments to blocked persons must be made either into Foreign Government Deposit Funds (i.e., funds paid to or held by the U.S. government on behalf of the Government of Venezuela and associated entities as specified in EO 14373), or any other account as instructed by the U.S. Treasury Department (except for certain payments for local taxes, permits, or fees as clarified in GL 46A). Further, any contract for transactions covered under GL 46 with the Government of Venezuela, PdVSA, or PdVSA entities must be governed by the laws of the United States or any jurisdiction within the United States, and contractual disputes must be resolved in the United States.

On February 3, 2026, OFAC then issued GL 47 authorizing the sale of U.S.-origin diluents to Venezuela. Unlike GL 46, GL 47 explicitly lists payment processing as an authorized support service - but it does contain similar restrictions on payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro, as well as entity location-based restrictions (e.g., transactions involving a person located in or organized under the laws of (or owned or controlled by) Iran, North Korea, and Cuba). The use of GL 47 by U.S. persons is also subject to certain specific U.S. government reporting requirements.

On February 10, 2026, OFAC issued GL 48 with sweeping authorizations for U.S. persons to provide goods, technology, software, or services for the exploration, development, or production of oil or gas in Venezuela, including certain transactions with PdVSA. Related transactions authorized under GL 48 include processing of payments, arranging shipping and logistics services, including chartering vessels, obtaining marine insurance and protection and indemnity coverage, and arranging port and terminal services, including with port authorities or terminal operators that are part of the Government of Venezuela. It also authorizes transactions for the maintenance of oil or gas operations in Venezuela, including the refurbishment or repair of items used for oil or gas exploration, development, or production activities.

GL 48 requires any such covered contracts with the Government of Venezuela, PdVSA, or PdVSA entities be governed by the laws of the United States or any jurisdiction within the United States, and that any dispute resolution under the contract occur in the United States.  Further, any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, must be made into the Foreign Government Deposit Funds, as specified in EO 14373.  Restrictions on GL 48 include transactions involving entities in Russia, Iran, North Korea, Cuba, or China (or any entity owned or controlled, by or in a joint venture, with such persons), as well as the formation of new joint ventures or other entities in Venezuela to explore or produce oil or gas. 

Most recently, on February 13, 2026 OFAC issued GL 49 and GL 50. 

GL 49 authorizes negotiations of and entry into contingent contracts for new investment in oil or gas sector operations in Venezuela – but importantly, GL 49 does not authorize performance of such contracts, which will be expressly contingent on separate OFAC approval. Such “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.”  These contracts can relate to both (i) negotiating and entering into contracts to engage in new oil or gas exploration, development, or production activities in Venezuela, expand existing operations in Venezuela, and to form new joint ventures or other entities in Venezuela related to the foregoing activities; and (ii) prefatory steps for such activities, such as conducting commercial, legal, technical, safety, and environmental due diligence and assessments.

GL 50 separately authorizes transactions that would be prohibited by the VSR related to the Venezuelan oil or gas sector with specific Venezuelan entities – including BP PLC, Chevron Corporation, Eni S.p.A., Repsol S.A., Shell PLC, and their subsidiaries. The use of GL 50 is subject to U.S. government reporting requirements, and any payments of oil or gas taxes or royalties to the Government of Venezuela, PdVSA, or any PdVSA entity must be paid into the Foreign Government Deposit Funds per EO 14373.

Key Takeaways

OFAC’s issuance of GLs 46-50 creates a broad variety of new opportunities for U.S. companies seeking to do business in Venezuela’s energy sector, but compliance risks still remain.  It is critical that businesses engaging in transaction activity pursuant to these new OFAC general licenses actively document their compliance with the specific requirements of each respective license authorization. Given the rapid pace of regulatory change targeting Venezuela and associated recent sanctions relief, we anticipate additional general licensing structures and guidance for U.S. companies operating in the region.

If you have any questions regarding OFAC sanctions on Venezuela or the application of the new VSR general licenses, please do not hesitate to reach out to a member of Womble Bond Dickinson’s Venezuela Task Force or International Trade Team. 

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