On June 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a suite of updated Venezuela-related general licenses (“GLs”) that slightly ease certain licensing conditions related to governing law and dispute resolution clauses in contracts involving the Government of Venezuela, Petróleos de Venezuela S.A. (“PdVSA”), CVG Compañía General de Minería de Venezuela CA (“Minerven”), or any entity in which PdVSA or Minerven owns, directly or indirectly, a 50% or greater interest. These updated GLs replace and supersede a number of general licenses issued earlier in 2026, namely GLs 46B (now 46C), 47 (now 47A), 48A (now 48B), 50A (now 50B), 51A (now 51B), 52 (now 52A), and 54 (now 54A) (collectively, “Venezuela GLs”).
In parallel, OFAC published two new Frequently Asked Questions (“FAQs”) clarifying (i) the scope of the governing law of the contracts authorized under the Venezuela GLs and (ii) the extent to which aviation-related transactions involving Venezuela are authorized.
Below we outline the key changes and practical implications.
I. Modifications to Venezuela GL Contractual Requirements
a. Governing Law of Contracts
Previously, the Venezuela GLs required that any contracts entered into or performed in reliance on the GLs be “governed” by “the laws of the United States or any jurisdiction within the United States.” Now, each of the Venezuela GLs instead requires that such contracts require that “the terms of the contract be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States.”
b. Applicable Venezuelan Laws and Regulations for Contracts
Each of the Venezuela GLs incorporates a new Note stating that contracts made in reliance on the Venezuela GLs can include contract terms that recognize that “certain aspects of the underlying activity in Venezuela may be subject to applicable Venezuelan law and regulations, including laws and regulations governing the exercise of Venezuela’s sovereign regulatory authority, administrative permits and licenses, concessions, labor, environmental, health and safety, and other mandatory regulatory requirements.”
c. Expanded Dispute Resolution Options
Previously, the Venezuela GLs only authorized dispute resolution in the United States. As amended, they allow parties to choose to hold dispute resolution proceedings not only in the United States, but also in the United Kingdom, France, or Singapore, which are jurisdictions frequently used as seats for international arbitration.
d. FAQ 1260
FAQ 1260 illustrates the narrow nature of these changes. Contracts entered into in reliance on the Venezuela GLs must still be “governed” by US law despite the deletion of the word “govern” from the Venezuela GLs, as OFAC states that “the laws of a state or other jurisdiction within the United States must govern questions of contract law between the parties relating to the contract, including interpretation, contractual performance obligations, breach, contractual remedies, payment obligations, termination, validity, assignment or novation, and enforceability of the contract” (emphasis added). But this requirement does not mean that the contract terms cannot account for the fact that certain activities related to contract performance in Venezuela may also be subject to Venezuelan law and regulations (e.g., licensing requirements, labor laws, environmental rules), provided that the parties’ obligations under the contract continue to be governed by US law.
II. FAQ 1259: Aviation Activities Involving Venezuela
OFAC has confirmed that private and commercial aviation activities involving Venezuela remain broadly authorized under GL 30B and GL 33, subject to certain limitations.
GL 30B authorizes US persons to engage in transactions with the Government of Venezuela that are ordinarily incident and necessary to airport operations, including:
- Ground handling and baggage services;
- Safety and security services;
- Airport operational services;
- Air navigation and overflight services;
- Fueling and into-plane services; and
- Payment of aeronautical, customs, immigration, and related fees.
GL 33 separately authorizes transactions involving the Government of Venezuela related to overflights, emergency landings, and air ambulance or medical evacuation services.
However, OFAC emphasizes that these authorizations do not extend to dealings with blocked persons, except in limited cases.
The FAQ also reiterates that non-US persons generally do not face sanctions exposure for engaging in activities that US persons are authorized to engage in, and notes that US sanctions programs typically do not prohibit transactions ordinarily incident to travel to or from any country.
