March 26, 2026

OFAC Issues Broad Authorizations for Dealings with PdVSA

Stephan Becker, Samantha Franks, Aaron Hutman, Erin Kwiatkowski, Matthew Rabinowitz, Daniel Steinfeld, Christopher Wall Pillsbury - Global Trade & Sanctions Law + Follow Contact LinkedIn Facebook X Send Embed

On March 18, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 52 (GL 52). The license broadly authorizes established U.S. entities to engage in transactions with Petróleos de Venezuela, S.A. (PdVSA)—including oil trading, new investment and the formation of joint ventures—while maintaining substantial restrictions on counterparties, payment structures, and debt- or equity-related transactions. OFAC simultaneously issued FAQ 1245 and FAQ 1246, which clarify the scope of authorized activities, confirm key exclusions, and address the license’s implications for high-profile enforcement matters.

Background
The Venezuela sanctions program has been built through a series of executive orders. In 2017, Executive Order 13808 restricted dealings in certain Venezuelan government debt. In 2018, Executive Order 13835 prohibited transactions related to the sale, transfer or pledging of equity interests in entities owned by the Government of Venezuela, including PdVSA. In January 2019, OFAC designated PdVSA under Executive Order 13850 as a Specially Designated National, and in August 2019, Executive Order 13884 expanded the program by blocking all property of the Government of Venezuela, including PdVSA and other state instrumentalities.

In early 2026, the Trump administration began issuing a series of general licenses providing targeted relief for transactions involving Venezuela’s oil and gas sector. Executive Order 14373 established the Foreign Government Deposit Funds mechanism for routing payments related to Venezuelan oil transactions. OFAC then issued a sequence of general licenses addressing discrete aspects of the energy sector. GL 52 now extends authorization for a wide range of PdVSA-related transactions by established U.S. entities.

General License 52 Authorizations
GL 52 authorizes all transactions otherwise prohibited by Executive Orders 13884 and 13850 involving PdVSA and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), but only when conducted by “established U.S. entities,” defined as entities organized under U.S. law on or before January 29, 2025. This mirrors a similar limitation in GL 46B, while certain other recent Venezuela-related general licenses do not include this restriction.

Activities authorized by GL 52 include:

• Lifting, exportation, sale, resale and transportation of Venezuelan-origin oil and petroleum products;
• Provision of diluent, goods, services and technologies necessary for exploration, development or production activities in Venezuela’s oil, gas or petrochemical sectors;
• Entry into new investment contracts for exploration, development or production activities;
• Formation of new joint ventures or other entities in Venezuela related to such activities; and
• All transactions ordinarily incident and necessary to these activities, including commercial, legal, technical, safety, and environmental due diligence and assessments. GL 52 also authorizes transactions involving the Government of Venezuela that would otherwise be prohibited under Executive Order 13884, provided such transactions are necessary for authorized activities and comply with the same payment-routing requirements.

FAQ 1245 provides additional guidance on GL 52, clarifying the scope of authorized transactions and confirming key exclusions. GL 52 does not authorize transactions related to PdVSA bonds or debt, equity interests in PDV Holding, CITGO Holding, or CITGO Petroleum Corp., or transactions involving SDN-listed individuals or entities.

Restrictions
GL 52 includes restrictions consistent with the other Venezuela general licenses issued in 2026. The license does not authorize transactions otherwise prohibited by the Venezuela Sanctions Regulations, including those involving PdVSA bonds, debt or equity interests in PdVSA and its subsidiaries, nor does it permit the enforcement of liens, judgments or arbitral awards that would transfer blocked property. Transactions involving blocked individuals or entities, other than PdVSA and PdVSA Entities, remain prohibited, as do transactions involving unreasonable payment terms.

GL 52 also imposes country-based counterparty restrictions. The license does not authorize transactions involving persons located in or organized under the laws of Russia, Iran, North Korea or Cuba, or entities owned or controlled by or in a joint venture with such persons. Separately, GL 52 excludes transactions involving Venezuelan or U.S. entities that are owned or controlled, directly or indirectly, by or engaged in a joint venture with persons located in or organized under the laws of the People’s Republic of China. Finally, the license does not authorize the unblocking of any property blocked under the Venezuela Sanctions Regulations or any transaction involving a blocked vessel.

Any contracts for transactions with PdVSA or PdVSA entities must specify that the contract is governed by U.S. law and that dispute resolution under the contract occur in the United States.

As noted above, any payments made to blocked persons, other than payments for local taxes, permits or fees, must be deposited into the Foreign Government Deposit Funds established under Executive Order 14373 or another Treasury-designated account. OFAC previously outlined the payment process for these funds in FAQ 1239. GL 52 also imposes a detailed reporting regime for transactions involving exports of Venezuelan-origin oil or petrochemical products to countries other than the United States.

Looking Ahead
GL 52 represents a significant expansion in the scope of authorized activity for established U.S. entities seeking to participate in Venezuela’s energy sector. That said, several important limitations warrant attention. Eligibility remains restricted to “established U.S. entities” organized before January 29, 2025, and the broader Venezuela sanctions framework remains in place at this time. The contractual requirements (U.S. governing law and U.S. dispute resolution), the payment-routing obligations, the country-based counterparty restrictions, and the reporting regime all require integration into compliance programs. Companies must also remain aware of other U.S. regulatory requirements, including export controls administered by the Bureau of Industry and Security.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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