On February 3, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 47 (“GL 47”) authorizing transactions related to the exportation/reexportation of US-origin diluents (i.e., diluting agents used to reduce viscosity of fluids, e.g., for use in crude oil pipelines) to Venezuela that would otherwise be prohibited under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. You can find our blog posts about developments under US sanctions targeting Venezuela since the capture of Nicolás Maduro here, here, here, here, and here.
Subject to certain conditions, GL 47 authorizes all transactions ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, marketing, delivery, or transportation of US-origin diluents to Venezuela, including transactions involving the following US-sanctioned parties:
- The Government of Venezuela (“GoV”);
- Petróleos de Venezuela, S.A. (“PdVSA”); and
- Any entity in which PdVSA owns, directly or indirectly, a 50% or greater interest (“PdVSA Entities”).
Transactions authorized by GL 47 include processing payments, arranging shipping and logistics services (including chartering vessels), obtaining marine insurance and protection and indemnity (P&I) coverage, and arranging port and terminal services, including with port authorities or terminal operators that are part of the GoV. However, in order to rely on GL 47, any contract with the GoV, PdVSA, or PdVSA Entities must specify that (1) the law of the United States or any jurisdiction within the United States will govern the contract and (2) any dispute resolution under the contract will occur in the United States.
GL 47 does not authorize the following:
- Payment terms that: (i) are not commercially reasonable, (ii) involve debt swaps or payments in gold, or (iii) are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the GoV, including the petro;
- Any transaction involving a person located in or organized under the laws of Iran, North Korea, Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a JV with, such persons;
- The unblocking of any property blocked pursuant to the Venezuela Sanctions Regulations, except as provided in paragraph (a) of GL 47; or
- Any transactions involving blocked vessels.
Lastly, GL 47 imposes reporting obligations on any person relying on the license authorization. Specifically, any person that exports, reexports, sells, resells, or supplies US-origin diluents to Venezuela pursuant to GL 47 must submit detailed reports identifying, for each transaction:
- The parties involved;
- The quantities and values of the diluents; and
- The dates the transactions occurred.
These reports must be submitted to both Sanctions_inbox@state.gov and VZReporting@doe.gov within ten days after execution of the first transaction, with subsequent reports required every 90 days thereafter for as long as such transactions remain ongoing.
As US policy regarding Venezuela continues to develop, it is possible that OFAC may issue new or expanded general licenses that go beyond GL 47’s current scope. We are closely monitoring these developments and will continue to update this blog as and when new actions are taken.
