OFAC Issues Venezuela Oil Trade General Licenses

Pillsbury Trade & Sanctions Blog

Published January 29th, 2026

Detected March 1st, 2026

Summary

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued General License (GL) 46, authorizing certain transactions related to Venezuelan oil and petroleum products for established U.S. entities. This action aims to expand trade and investment opportunities, though broader sanctions remain in place.

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What changed

OFAC has issued General License (GL) 46, effective January 29, 2026, authorizing "established U.S. entities" to engage in transactions related to the sale, purchase, and export of Venezuelan oil and petroleum products. An "established U.S. entity" is defined as one organized under U.S. law on or before January 29, 2025. The license permits transactions ordinarily incident and necessary to the oil trade, including refining, and specifies that these must be carried out by the U.S. entity, though non-U.S. persons can provide supporting services.

Regulated entities, particularly established U.S. companies involved in the energy sector, must review GL 46 and associated FAQ guidance to understand the scope of authorized activities. While this license provides new opportunities, it is crucial to ensure compliance with the specific terms, including the definition of an "established U.S. entity" and the requirement for transactions to be conducted by the U.S. entity itself. Failure to adhere to the license's conditions could result in sanctions violations.

What to do next

Review OFAC General License 46 and related FAQ guidance.
Verify status as an "established U.S. entity" organized on or before January 29, 2025.
Ensure all authorized transactions are conducted by the U.S. entity, not non-U.S. affiliates.

Source document (simplified)

Christopher R. Wall Stephan E. Becker Aaron R. Hutman Matthew R. Rabinowitz Zachary C. Rozen Samantha Franks Erin Kwiatkowski Marcus Burden Daniel Steinfeld Following the removal of Venezuelan President Nicolás Maduro on January 3, 2026, the Trump administration has taken actions to expand Venezuela-related oil trade and investment opportunities, primarily for U.S. companies.

While the broader framework of U.S. sanctions for Venezuela’s regime remains in place, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has issued two General Licenses (GLs) that authorize certain transactions relating to Venezuelan-origin oil and petroleum products, as well as U.S.-origin diluents.

GL 46 Authorizations On January 29, 2026, OFAC issued GL 46, which authorizes “established U.S. entities” to engage in certain transactions involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), and associated entities that are “ordinarily incident and necessary to the lifting, sale or resale, supply, storage, marketing, purchase, delivery and transportation and export/reexport of Venezuelan oil, including refining such oil.” On February 6, 2026, OFAC issued FAQ guidance to clarify the two general licenses.

GL 46 defines “established U.S. entity” as an entity organized under U.S. law on or before January 29, 2025. The text of the GL indicates that transactions must be carried out by the U.S. entity and not by any non-U.S. affiliate. However, non-U.S. persons can provide the various services, financial transactions and logistics that are ordinarily incident and necessary to carry out the transactions.

According to FAQ 1226, “Venezuelan oil” includes crude oil as well as other petroleum products, which are defined to include “unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas, and miscellaneous products obtained from the processing of crude oil (including lease condensate), natural gas, and other hydrocarbon compounds.” OFAC clarified that the authorization includes Merey 16 or bitumen blends, as well as petroleum products or byproducts, including gasoline, asphalt, flexicoke, and petroleum coke. However, petroleum products do not include natural gas, liquefied natural gas, biofuels, methanol, and other non-petroleum fuels.

Certain support services also are authorized, including services related to shipping, marine insurance, and arranging port and terminal services. OFAC has stated that downstream trading activities, coordinating payment structures, and financing related cargos or receivables also are activities covered by GL 46. The general license does not authorize exploration activity or negotiations for new investment in the Venezuelan oil sector.

GL 46 Conditions GL 46 imposes strict conditions on payments made pursuant to its authorization. Payment terms must be commercially reasonable and are subject to limitations on the use of digital payments and the petro. Any payments to blocked persons must be made either into Foreign Government Deposit Funds, or any other account as instructed by the U.S. Treasury Department. “Foreign Government Deposit Funds” are defined by Executive Order (E.O.) 14373 as funds paid to or held by the U.S. government on behalf of the Government of Venezuela and associated entities, including PdVSA, that are derived from sales of natural resources from, or the sale of dilutents to, the Government of Venezuela and associated entities. Pursuant to E.O. 14373, the funds are the property of the Venezuelan Government and are held by the U.S. Government in a solely custodial capacity. The funds cannot be transferred or otherwise dealt in absent further authorizations under E.O. 14373.

Transactions also generally may not involve entities affiliated with Russia, Iran, Cuba, the Democratic People’s Republic of Korea (DPRK), and the People’s Republic of China (PRC). However, FAQ 1231 clarifies that GL 46 does not restrict the resale of Venezuelan oil to China by established U.S. entities.

Entities selling Venezuelan-origin oil must provide a detailed report for each transaction made pursuant to GL 46.

GL 47 Authorizations On February 3, 2026, OFAC issued GL 47, authorizing the sale of U.S.-origin diluents to Venezuela. GL 47 does not limit authorizations to “established U.S. entities” and also does not contain the GL 46 limitation on transactions with PRC-affiliated entities. Unlike GL 46, GL 47 explicitly lists payment processing as an authorized support service. The reporting requirement in GL 47 is narrower as well, as only persons who sell U.S.-origin diluents to Venezuela are required to report.

Looking Forward U.S. policy is evolving and announcements from the White House, Department of Energy and OFAC bear watching. Further general licenses reportedly are under consideration and OFAC’s approach to further specific licenses is developing. For companies operating under general licenses, careful transaction structuring and compliance will be essential.

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