On March 13, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) expanded the scope of three existing general licenses (“GLs”) and issued two amended Frequently Asked Questions (“FAQs”) related to certain imports and activities involving electricity and petrochemicals in Venezuela. On March 18, 2026, OFAC also issued a new GL authorizing transactions with Venezuelan state-owned Petróleos de Venezuela, S.A. (“PdVSA”), subject to certain conditions, and issued two new FAQs related thereto.
Amended GLs and FAQs
GL 46B – Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products
- GL 46B replaces and supersedes GL 46A. Our prior blog posts on GL 46A and GL 46 are available here and here, respectively.
- GL 46B expands the existing authorization related to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, to also cover Venezuela-origin petrochemical products for importation into the United States by an established US entity (i.e., an entity organized under US law on or before January 29, 2025).
- The term “petrochemical products” includes fertilizer products and fertilizer precursor chemicals, including the chemicals listed in the Annex to GL 46B.
GL 48A – Authorizing the Supply of Certain Items and Services to Venezuela
- GL 48A replaces and supersedes GL 48. Our prior blog post on GL 48 is available here.
- GL 48A expands the existing authorization related to the provision of certain items and services to Venezuela to also cover petrochemical products in Venezuela, as well as items for the generation, transmission, storage, or distribution of electricity in Venezuela.
GL 49A – Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela
- GL 49A replaces and supersedes GL 49. Our prior blog post on GL 49 is available here.
- GL 49A expands the existing authorization related to the negotiation and entry into “contingent contracts” involving the Government of Venezuela (“GOV”), PdVSA, or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (“PdVSA Entities”) to also cover the petrochemical products and electricity sectors in Venezuela.
- However, GL49A does not authorize the performance of such contracts, which must be made expressly contingent on obtaining separate authorization from OFAC.
New GL and FAQs
GL 52 – Authorizing Certain Transactions Involving PdVSA
- GL 52 authorizes all transactions prohibited by Executive Order (“EO”) 13884 (which imposed blocking sanctions on the GOV) or EO 13850 (which imposed blocking sanctions on PdVSA) involving PdVSA or PdVSA Entities by an established US entity, provided that certain conditions (discussed below) are met.
- GL 52 appears to be intended to cover all transactions involving PdVSA that were not already authorized by the other new Venezuela GLs related to oil and gas (including petrochemicals). In connection with the issuance of GL 52, the Treasury Department posted on social media that GL 52 is intended to “support[] the global energy market by increasing the available supply of available oil. It will also help incentivize new investment in Venezuela’s energy sector.” This indicates that one of the primary purposes of the license is to try to stabilize increasing oil and gas prices.
- Notably, GL 52 authorizes the entry into new investment contracts for exploration, development, or production activities in the Venezuela oil and gas sectors. This means that GL 49A is likely moot with respect to PdVSA and PdVSA Entities, as US persons would no longer need to rely on it to enter into contracts with such entities. That said, the practical impact of GL 52 may be limited in that GL 52 does not authorize transactions involving the GOV other than those necessary for the activities set forth in the license. For example, activities involving other GOV owned industries would not be authorized (e.g., mining, electricity generation) beyond what the existing GLs cover.
- Requirements related to contractual safeguards, payment terms, and reporting requirements, including a requirement that any contract with PdVSA or PdVSA Entities be governed by US law and be subject to dispute resolution in the United States;
- Restrictions related to transactions involving any individual or entity on the SDN List, other than PdVSA and PdVSA Entities;
- Restrictions related to transactions related to bonds and certain other government debt of the GOV or PdVSA and transactions related to the sale, transfer, assignment or pledging as collateral by the GOV of equity interest in PdVSA, PdVSA Entities, or other entities owned 50 percent or more by the GOV;
- GL 52 only overcomes prohibitions related to EOs 13884 and 13850 and expressly does not authorize dealings in PdVSA “new debt” issued after August 25, 2017 that are prohibited under EO 13808.
- Only an “established US entity” may rely on GL 52, which has the same definition as it does in GL 46B; and
- Any payments to the GOV, PdVSA, or PdVSA Entities, except for local taxes, permits, or fees, must be made into the Foreign Government Deposit Funds accounts.
Like other recently issued Venezuela GLs, GL 52 contains certain reporting requirements and restrictions, including:
The new FAQs provide further guidance on the scope and application of GL 52.
- FAQ 1245 provides a list of activities that are authorized and not authorized by GL 52. This list generally overlaps with the activities already authorized by the existing Venezuela GLs.
- FAQ 1246 clarifies that GL 52 does not authorize the sale of certain shares of CITGO that are the subject of the case Crystallex International Corporation v. Bolivarian Republic of Venezuela. A specific license from OFAC is required before any sale is executed in the Crystallex case.
