On April 14, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC“) issued two new general licenses (“GLs“) — GL 56 and GL 57, which further ease longstanding US sanctions targeting Venezuela. OFAC also issued a new Frequently Asked Question (“FAQ”) to clarify the scope of the reporting requirements included in several Venezuela-related GLs. These GLs address certain gaps in the previous sanctions framework and removal of certain restrictions by broadening the scope of permissible pre-transaction negotiations and allowing certain payments to flow through the named Venezuelan state banks.
Our prior blog posts related to the ongoing developments and relaxations of sanctions targeting Venezuela are available here, here, and here.
- New General License 56
The new GL 56 authorizes transactions that are ordinarily incident and necessary to the negotiation of “contingent contracts” with the Government of Venezuela (“GOV”). GL 56 does not, however, authorize the entry into or performance of such contracts, which must be made expressly contingent on obtaining separate authorization from OFAC. Consistent with recently issued GL 49A, “contingent contracts” for purposes of GL56 “includes 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.” (see our previous blog post regarding the issuance of GL 49A here).
Like other recently issued Venezuela GLs, GL 56 contains certain limitations. For example, GL 56 does not authorize:
- Payment terms that are not commercially reasonable, involve debt swaps or gold payments, or are denominated in Venezuelan digital currency including the petro.
- Transactions involving a person located in Russia, Iran, North Korea, Cuba, or any entity owned or controlled by or in a joint venture with such persons.
- Transactions involving US or Venezuelan entities owned or controlled by or in a joint venture with a person located or organized under the laws of China.
2. New General License 56
The new GL 57 authorizes transactions that are ordinarily incident and necessary to the provision of “financial services,” directly or indirectly, to, from, for the benefit of:
- The following Venezuelan state banks (collectively, “Covered Banks”):
- Banco Central de Venezuela,
- Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela),
- Banco Digital de los Trabajadores Banco Universal C.A., and
- Banco del Tesoro, C.A. Banco Universal (Banco del Tesoro);
- any entity 50% or more owned by one or more of the Covered Banks; or
- Any individuals whose property and property interests are blocked solely pursuant to EO 13884 because the individual meets the definition of GOV under EO 13884 (i.e., for acting for or behalf of the GOV), including current GOV employees, provided that such individuals are not listed as Specially Designated Nationals (SDNs).
GL 57 defines the term “financial services” to include a broad range of banking and payment related activities, such as maintaining and operating accounts, providing banking services, transferring funds, issuing loans, and processing or receiving employment-related payments or benefits.
GL 57 also authorizes transactions involving the GOV that are necessary for the activities authorized above.
Further, GL 57 provides a safe harbor for US financial institutions. Specifically, US financial institutions processing transactions pursuant to this GL may rely on representations from the originator or beneficiary that the transaction is made in compliance with the GL, provided that the processing institution does not know or have reason to know that the transaction is not compliant with GL 57.
3. FAQ 1248
FAQ 1248 addresses which parties are responsible for complying with the reporting requirements included in several of the Venezuela-related GLs issued since January 2026, such as GLs 48A and 50A. The FAQ clarifies that the parties engaged in the “primary authorized activity” under a GL triggering reporting requirements (e.g., a specific service authorized under GL 48A) are responsible for complying with those requirements. Parties that are only indirectly involved or providing an ancillary service (e.g., processing a payment related to the service authorized under GL 48A), are not subject to the reporting requirement.
