OFAC Issues New General Licenses 52, 54, 55 for Venezuela

April 14, 2026

OFAC continues to expand authorizations for Venezuela-related transactions through new and amended general licenses

Cassady Cohick, Aleksandar Dukic, Nicki Ghazarian-Foye, Ajay Kuntamukkala, Deborah Wei Hogan Lovells + Follow Contact LinkedIn Facebook X Send Embed

Key takeaways

Since our prior report on March 13, 2026, OFAC has issued and amended multiple Venezuela-related general licenses, significantly expanding authorized activity—most notably through newly issued General Licenses 52, 54, and 55.

The new licenses broaden authorizations across the oil, gas, petrochemical, electricity, and critical minerals and mining sectors, with important conditions and reporting obligations.

Companies considering activity in reliance on these licenses should continue to assess existing compliance frameworks and payment structures in light of OFAC’s updated guidance.

As we reported here, beginning in late January 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued several Venezuela-related General Licenses (GLs) that meaningfully expand the scope of authorized transactions in the oil and gas, and critical minerals industries, involving the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (PdVSA), and other blocked Venezuelan entities. Since our prior publication, OFAC has issued several new and amended Venezuela-related GLs with notable implications for U.S. businesses, as described further below.

Overview of Venezuela-related general licenses issued or amended since March 12, 2026

• GL 46 (January 29, 2026): Authorizing Certain Activities Involving Venezuelan-Origin Oil and Petrochemical Products; subsequently replaced by GL 46A (February 10, 2026) and then GL 46B (March 13 ,2026)
• GL 48 (February 10, 2026): Authorizing the Supply of Certain Items and Services to Venezuela; subsequently replaced by GL 48A (March 13, 2026)
• GL 49 (March 13, 2026): Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela; subsequently replaced by GL 49A (March 13, 2026)
• GL 51A (March 27, 2026): Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold
• GL 52 (March 18, 2026): Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.
• GL 54 (March 27, 2026): Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela
• GL 55 (March 27, 2026): Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Minerals Sector

Venezuela-related general licenses’ authorizations and associated frequently asked questions

Below discusses the changes between the original and amended GLs described above, as well as provides the specific activities authorized by the new GLs 52, 54, and 55, and associated Venezuela-related Frequently Asked Questions (FAQs).

General licenses authorizing activities within the oil and gas sector

Amended GLs 46B, 48A, and 49A and Associated OFAC FAQs

Below provides a brief recap of our prior article discussing the transactions authorized by GLs 46, 48, and 49:

• GL 46/46A authorizes transactions otherwise prohibited by the Venezuela Sanctions Regulations (the VSR, 31 C.F.R. Part 591), including those involving GOV, PdVSA, or any entity in which PdVSA owns 50 percent or more, directly or indirectly (collectively, “PdVSA Entities”), that are ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, including the refining of such oil, when conducted by an “established U.S. entity.”
• GL 48 authorizes all transactions prohibited by the VSR, including those involving GOV, PdVSA, or PdVSA Entities, that are ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, or production of oil or gas in Venezuela.
• GL 49 authorizes all transactions prohibited by the VSR, including those involving GOV, PdVSA, and PdVSA Entities, that are related to the negotiation of and entry into contingent contracts for new investment in oil or gas sector operations in Venezuela, provided that the performance of any such contract is made expressly contingent upon separate authorization from OFAC. GLs 46B, 48A, and 49A were amended to authorize transactions for petrochemical products, in addition to oil and gas, as well as transactions for the “generation, transmission, storage, or distribution of electricity in Venezuela.” Prior GLs 46A, 48, and 49 have been replaced and superseded in their entirety by these amended General Licenses.

Associated OFAC FAQs 1226 and 1227 were also amended to reflect the widened scope of these GLs. OFAC FAQ 1226 notes that reference to Venezuelan-origin petrochemical products also includes fertilizer and certain precursor chemicals that are identified in the Annex of GL 46B. FAQ 1226 also confirms that GL 46B encompasses crude oil blends and petroleum products, as defined by the U.S. Energy Information Administration. 1 OFAC FAQ 1227 reiterates that activities authorized by GL 46B are expanded to include both Venezuelan-origin oil and petrochemical products.

GL 52: Authorizing Certain Transactions Involving Petroleos de Venezuela, S.A.

On March 18, 2026, OFAC issued a broad new GL 52 that authorizes transactions between U.S. entities and PdVSA and its subsidiaries/joint ventures. This significantly broadens the scope of transactions that were authorized under prior issued GLs, such as GL 46B.

• GL 52 authorizes transactions otherwise prohibited by Executive Order (E.O.) 13884 or E.O. 13850 involving PdVSA, or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), by an “established U.S. entity.”
• Associated OFAC FAQs describing GL 52 include the following:
  • OFAC FAQ 1245 states that the activities authorized may include:
  • “[T]he lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan oil or petroleum products of Venezuelan-origin oil and petroleum products;
  • [T]he provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors;
  • [E]ntry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products sectors of Venezuela;
  • [T]he formation of new joint ventures or other entities in Venezuela related to such activities; and
  • [A]ll transactions ordinarily incident and necessary to such activities, including the performance of commercial, legal, technical, safety, and environmental due diligence and assessments related to the foregoing.”
  • However, as clarified in OFAC FAQ 1245, GL 52 does not authorize the following transactions that would otherwise be prohibited by the VSR, and associated E.O. 13808 and E.O. 13835. These include:
  • Transactions related to bonds and debt issued by, and equity interest in, PdVSA and its subsidiaries;
  • Transactions involving a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;
  • Transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China (China);
  • Transactions involving blocked vessels;
  • Transactions involving the transfer of equity interest in PDV Holding, CITGO Holding, or CITGO Petroleum Corp.; or
  • Transactions involving individuals or entities on the Specially Designated Nationals and Blocked Persons list (SDN List).

• Use of this GL gives rise to reporting obligations to the U.S. Department of State (State) and the U.S. Department of Energy (DoE).
  Relatedly, on March 31, 2026, OFAC issued FAQ 1247 confirming that non-U.S. persons will not face secondary sanctions risk for engaging in transactions authorized by GLs 46B, 51A (which is discussed further below), and 52, provided such individuals comply with the conditions outlined in each GL. These include the following:

• “The non-U.S. entity was organized under the laws of a third country on or before January 29, 2025;

• Any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury;

• The payment terms are commercially reasonable;

• The payment terms do not involve debt swaps, and are not denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;

• The transaction does not involve a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People's Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;

• The transaction does not involve an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People's Republic of China;

• The transaction does not involve a blocked vessel; and

• With respect to GL 51A, the transaction does not involve the processing or refining of Venezuelan-origin minerals, including gold, in the Russian Federation, the Islamic Republic of Iran, the Democratic People's Republic of Korea, the Republic of Cuba, or the People's Republic of China.”

General licenses authorizing activities within the mining and critical minerals sector

Amended GL 51A: Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold

• GL 51A supersedes and replaces in its entirety GL 51, dated March 6, 2026.
• GL 51A amended GL 51 to broaden the scope of authorized activities to include transactions involving other Venezuelan-origin minerals, in addition to gold, and to encompass activities related to the reexportation, resale, processing, and or refining of these minerals.
• GL 51A authorizes transactions, otherwise prohibited by the VSR, and including those involving the GOV, CVG Compania General de Mineria de Venezuela CA (“Minerven”), or any entity in which Minerven owns, directly or indirectly, a 50 percent or greater interest (collectively, “Minerven Entities”), that are ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin minerals, including gold, by an established U.S. entity.
  • Such authorized transactions include the following:
  • Conducting commercial, legal, technical, safety, and environmental due diligence and assessments ordinarily incident to the activities noted above; and
  • Arranging shipping and logistics services, including chartering vessels, arranging security services, obtaining marine insurance and protection and indemnity (P&I) coverage, and arranging port and terminal services, including with port authorities or terminal operators that are part of the Government of Venezuela.
  • GL 52 does not, however, authorize the following transactions related to the processing and/or refining of such minerals:
  • Transactions with payment terms that are not commercially reasonable;
  • Transactions involving a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;
  • Transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of China;
  • Transactions involving the processing or refining of Venezuelan-origin minerals, including gold, in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or China;
  • Transactions involving blocked vessels; or
  • Exploration, development, mining, extraction, processing, refining, or production of minerals in Venezuela or the formation of joint ventures or other entities in Venezuela to engage in the foregoing activities.

• Use of this GL gives rise to reporting obligations to State and the U.S. Department of the Interior (DOI).
  GL 54: Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela

• GL 54 authorizes transactions otherwise prohibited by the VSR involving the GOV, Minerven, or Minerven entities that are ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, mining, extraction, processing, refining, or production of minerals, including gold, in Venezuela.

• Transactions that are authorized by this GL include the following:

  • Processing of payments;
  • Arranging shipping and logistics services, including chartering vessels, obtaining marine insurance and P&I coverage;
  • Arranging port and terminal services, including with GOV port authorities or terminal operators; and
  • Maintaining mineral operations, including gold operations, in Venezuela, such as the refurbishment or repair of items used for minerals exploration, development, mining, extraction, processing, refining or production activities.

• Transactions that are not authorized by this GL include:

  • Transactions with payment terms that are not commercially reasonable;
  • Transactions involving the formation of new joint ventures or other entities in Venezuela to explore, develop, mine, extract, process, refine, or produce minerals, including gold;
  • Transactions involving a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons; or
  • Transactions involving blocked vessels.

• Transactions must include “commercially reasonable” payment terms, as defined in OFAC FAQ 1232, which is also discussed in our prior alert issued in March 13, 2026.

• Use of this GL gives rise to reporting obligations to State and DOI.
  GL 55: Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Minerals Sector

• GL 55 authorizes all transactions otherwise prohibited by the VSR, including those involving the GOV, Minerven, or any entity in which Minerven owns, directly or indirectly, a 50 percent or greater interest, related to the negotiation of and entry into contingent contracts for new investment in the minerals sector of Venezuela, provided that the performance of such a contract is expressly contingent on separate authorization from OFAC.

• GL 55 defines the term “contingent contracts” as those including:

  • Executory contracts;
  • Executory pro forma invoices;
  • Agreements in principle; and
  • Executory offers capable of acceptance, e.g., bids, proposals in response to public tenders, binding memoranda of understanding, or a similar agreement. While these GLs continue to present exciting opportunities for U.S. companies, each authorization retains significant restrictions and companies considering activity under these new and amended authorizations should conduct careful review.

References

1 “As defined by the U.S. Energy Information Administration (EIA), petroleum products 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. In keeping with the EIA's standard definition, petroleum products do not include natural gas, liquefied natural gas, biofuels, methanol, and other non-petroleum fuels.” OFAC FAQ 1226.

[View source.]

Send Print Report

Related Posts

• OFAC issues guidance on sham transactions and sanctions evasion
• OFAC settles $3.7 million enforcement action for apparent violations of Syria sanctions
• OFAC lifts certain sanctions on Syria, broad export controls remain in place

Latest Posts

• OFAC continues to expand authorizations for Venezuela-related transactions through new and amended general licenses
• All change: Reform of the UK Financial Ombudsman Service and the redress system See more »

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.
Attorney Advertising.

©
Hogan Lovells

Written by:

Hogan Lovells Contact + Follow Cassady Cohick + Follow Aleksandar Dukic + Follow Nicki Ghazarian-Foye + Follow Ajay Kuntamukkala + Follow Deborah Wei + Follow more less

PUBLISH YOUR CONTENT ON JD SUPRA

• ✔ Increased readership
• ✔ Actionable analytics
• ✔ Ongoing writing guidance Join more than 70,000 authors publishing their insights on JD Supra

Start Publishing »

Published In:

Department of Energy (DOE) + Follow Economic Sanctions + Follow Energy Sector + Follow Executive Orders + Follow General Licenses + Follow International Trade + Follow Minerals + Follow Mining + Follow New Regulations + Follow Office of Foreign Assets Control (OFAC) + Follow Oil & Gas + Follow Reporting Requirements + Follow Sanctions + Follow U.S. Treasury + Follow Venezuela + Follow Energy & Utilities + Follow Finance & Banking + Follow International Trade + Follow more less

Hogan Lovells on:

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: Sign Up Log in ** By using the service, you signify your acceptance of JD Supra's Privacy Policy.* - hide - hide