Since August 21, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC“) has made a series of changes to the Venezuela-related general licenses (“GLs“) issued under the Venezuela Sanctions Regulations, 31 CFR part 591 (“VSR“). OFAC removed the US governing-law condition from the GLs that included it and updated the associated Frequently Asked Questions (“FAQs“). It issued two new GLs, (General License No. 61 (“GL 61“), since replaced by GL 61A, and General License No. 62 (“GL 62“)) related the telecommunications sector and extended the minerals-related GLs to include Venezuelan-origin coal. Each is summarized below.
Removal of the Governing-Law Condition from Venezuela GLs
On August 27, 2026, OFAC amended eight Venezuela GLs (GLs 46D, 47B, 48C, 50C, 51C, 52B, 54B, and 61A) and reworked the associated FAQ set, as announced here. The key change with these amendments is that contracts with the Government of Venezuela (“GOV“) and certain other blocked persons authorized under these GLs no longer need to include a clause requiring the contract to be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States. FAQ 1267 confirms the removal and states that OFAC acted in response to investment-related reforms made by the GOV since January 2026.
The forum-selection condition is unaffected in these GLs. FAQ 1268 confirms that the identified GLs continue to require any contract for authorized transactions with the GOV or certain other blocked persons to specify that dispute resolution proceedings occur in the United States, the United Kingdom, France, or Singapore. For our discussion of the June 2026 governing-law and dispute-resolution changes, see our previous blog post here.
New Telecommunications GLs
On August 21, 2026, OFAC issued GL 61 and GL 62, extending to telecommunications the two-track licensing structure it has used in other sectors of the Venezuela program this year, as announced here. On August 27, 2026, OFAC amended GL 61 with GL 61A, which authorizes transactions otherwise prohibited by the VSR, including transactions involving the GOV, the Comisión Nacional de Telecomunicaciones, and the Compania Anonima Nacional Telefonos de Venezuela, that are ordinarily incident and necessary to the provision from the United States or by a US person of goods, technology, software, or services for the installation, maintenance, refurbishment, repair, upgrade, operation, or support of telecommunications in Venezuela. It carries the forum-selection proviso, a set of counterparty and payment-term exclusions, and a periodic reporting condition running to the State Department. FAQ 1266 describes the scope with examples ranging from network equipment and spare parts to capacity and infrastructure leases, international connectivity, cloud services, and customer billing systems, and confirms that Movilnet is within scope although it is not named in the GL.
GL 62 authorizes the negotiation of and entry into contingent contracts for new investment in Venezuela’s telecommunications sector, including contracts to establish new telecommunications service providers, to expand existing operations, and to form new joint ventures, provided that performance of any such contract is made expressly contingent on separate authorization from OFAC. Amended FAQ 1244 indicates that OFAC will assess specific license applications to perform contingent contracts on a case-by-case basis, so companies negotiating contingent telecommunications contracts should consider drafting to the conditions OFAC has been building into the recent Venezuela GLs rather than waiting until the application stage.
GL 61A builds on the preexisting telecommunications authorization in GL 24A, which OFAC first issued as GL 24 on August 5, 2019 and reissued in amended form on June 18, 2026 (see our previous blog post here). There appears to be some overlap between the new GLs and GL 24A’s authorization for transactions involving the GOV incident to the receipt and transmission of telecommunications.
Coal Added to Mineral-Related GLs
On September 2, 2026, OFAC amended the minerals-related GLs to bring coal within their scope, issuing GL 51D, GL 54C, and GL 55A, and amending FAQ 1247, as announced here. We have covered the Venezuela minerals GLs previously; see our previous blog posts here and here. Each of the three GLs substitutes “coal or minerals” for “minerals,” and GL 51D and GL 54C name Carbones del Zulia S.A., a GOV coal company, in the operative text alongside CVG Compañía General de Minería de Venezuela CA. GL 51D authorizes certain activities involving Venezuelan-origin coal or minerals, including gold; GL 54C authorizes the supply of certain items and services for coal or minerals operations in Venezuela; and GL 55A authorizes negotiations of and entry into contingent contracts for certain investment in Venezuela’s coal or minerals sectors.
We will continue to monitor and update on any further developments in US policy on sanctions and export controls applicable to Venezuela.
