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OFAC Issues General Licenses for PdVSA Transactions

Crowell & Moring Trade Blog

Published March 18th, 2026

Detected March 24th, 2026

Summary

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued two new general licenses authorizing most previously prohibited transactions involving Petróleos de Venezuela, S.A. (PdVSA) and its entities, as well as further transactions related to a specific PdVSA bond. These licenses represent a significant shift from previous, more narrowly focused authorizations.

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What changed

OFAC has issued General License No. 52 (GL 52) and General License No. 5V, significantly broadening the scope of authorized transactions involving Petróleos de Venezuela, S.A. (PdVSA) and its associated entities. GL 52 permits most transactions previously prohibited by Executive Orders 13884 and 13850, including those related to the export, sale, supply, and development of Venezuelan oil and petroleum products, as well as the formation of new joint ventures. This represents a departure from prior general licenses that were limited to specific activities and sectors.

Compliance officers should note the stringent conditions attached to GL 52. Authorized transactions must be conducted by an "established U.S. entity" (organized on or before January 29, 2025), contracts must be governed by U.S. law with U.S. dispute resolution, and payments to blocked persons must be directed to specific Treasury-approved accounts. Crucially, GL 52 does not authorize transactions prohibited by other sanctions related to Venezuelan debt or equity interests. Entities engaging in these transactions must ensure strict adherence to these conditions to avoid violations.

What to do next

Review GL 52 and GL 5V for applicability to current and prospective transactions involving PdVSA.
Ensure all transactions involving PdVSA entities meet the "established U.S. entity" and contract requirements.
Verify that payments to blocked persons are directed to the specified Foreign Government Deposit Funds or as otherwise instructed by OFAC.

Source document (simplified)

On March 18 and 19, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two new Venezuela-related general licenses: General License No. 52 (GL 52), authorizing most previously prohibited transactions involving Petróleos de Venezuela, S.A. (PdVSA) and General License No. 5V (GL 5V), authorizing further transactions related to the PdVSA 2020 8.5 Percent Bond issued on or after May 5, 2026.

Background: In 2018, OFAC imposed debt-related sanctions on PdVSA – Venezuela’s state-run oil company, which OFAC supplemented on January 28, 2019 by designating PdVSA on the List of Specially Designated Nationals and Blocked Persons (SDN List). Then, on August 5, 2019, OFAC’s imposition of asset-freezing sanctions on the Government of Venezuela, PdVSA’s parent entity, resulted in a third set of sanctions applying to PdVSA.

Change in Dynamic: Since January 2026, OFAC has issued a series of general licenses authorizing certain U.S. persons to conduct business with PdVSA, the Government of Venezuela, and other sanctioned Venezuelan persons. Yet, those general licenses focus exclusively on select activities for preidentified sectors. These new general licenses change that approach.

New General License 52: GL 52 authorizes all transactions prohibited by Executive Order (E.O.) 13884 (the E.O. authorizing the imposition of asset-freezing sanctions on PdVSA) or E.O. 13850 (the E.O. authorizing the imposition of asset-freezing sanctions on the Government of Venezuela), if those transactions involve PdVSA, or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”). A follow-on FAQ (OFAC FAQ 1245) from OFAC explains that this authorization includes activities related to

the 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;
the provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors;
entry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products sectors of Venezuela;
the formation of new joint ventures or other entities in Venezuela related to such activities; and
all 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.
Conditions for GL 52: However, similar to the other recently issued general licenses, there are stringent conditions.
The authorized transactions must be conducted by an “established U.S. entity.” For purposes of GL 52, the term “established U.S. entity” means any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.
Any contract with PdVSA or PdVSA entities must be governed by U.S. law and provide for dispute resolution in the United States.
Any monetary payment to a blocked person — other than local taxes, permits, or fees — must be directed into the Foreign Government Deposit Funds as specified in E.O. 14373 of January 9, 2026, or another account as instructed by the U.S. Department of the Treasury.
GL 52 does not authorize transactions otherwise prohibited by U.S. sanctions on Venezuela, such as transactions prohibited by E.O. 13808 related to bonds and certain other debt of the Government of Venezuela or PdVSA, nor transactions prohibited by E.O. 13835 related to the sale, transfer, assignment, or pledging as collateral of any equity interest in PdVSA, PdVSA Entities, or any other entity in which the Government of Venezuela holds a 50 percent or greater ownership interest.
GL 52 also does not authorize settlement agreements, enforcement of liens, judgments, arbitral awards, or other judicial processes purporting to transfer blocked property.
All terms must be commercially reasonable payment terms and cannot include debt swaps, payments in gold or Venezuelan digital currency (including the petro).
Transactions cannot involve persons located in or organized under the laws of Russia, Iran, North Korea, or Cuba, entities owned, controlled, or in a joint venture with persons in those jurisdictions or in China, or other persons subject to U.S. sanctions other than PdVSA itself or PdVSA Entities.
Lastly, any person that exports, reexports, sells, resells, or supplies Venezuelan-origin oil or petrochemical products to countries other than the United States under GL 52 must submit detailed reports to Sanctions_inbox@state.gov and VZReporting@doe.gov, within ten days of the first such transaction, with follow-on reports required every 90 days while transactions remain ongoing. In GL 52, OFAC describes what must be in the report.
Updated General License 5V: GL 5V separately authorizes, on or after May 5, 2026, all transactions related to, the provision of financing for, and other dealings in the PdVSA 2020 8.5 Percent Bond that would otherwise be prohibited by E.O. 13835, as amended by E.O. 13857. OFAC has a long history of issuing an iteration of GL 5 and replacing it by a subsequent authorization, which has had the impact of delaying the effective date since the very first replacement of GL 5 in October 2019.

Companies should continue to monitor OFAC’s Venezuela sanctions program for any further amendments, revocations, or supplemental guidance affecting the scope of GL 52 and GL 5V. Relevant requirements under other federal authorities, including the Export Administration Regulations (EAR) remain in effect – companies should therefore continue to assess whether equipment, technology, or services associated with oil activity implicate export licensing, end-use, or end-user restrictions, particularly where transactions involve sensitive jurisdictions or intermediaries.

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Source

Crowell & Moring Trade Blog cmtradelaw.com

Trade & Sanctions

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency

FCC Industry Analysis

Published

March 18th, 2026

Instrument

Guidance

Legal weight

Binding

Stage

Final

Change scope

Substantive

Document ID

General License No. 52 / General License No. 5V

Who this affects

Applies to

Importers and exporters Investors Financial advisers

Industry sector

2111 Oil & Gas Extraction 5221 Commercial Banking 5231 Securities & Investments

Activity scope

International Trade Oil & Gas Extraction Financial Services

Threshold

Transactions must be conducted by an "established U.S. entity" (organized on or before January 29, 2025); contracts must be governed by U.S. law with U.S. dispute resolution; payments to blocked persons must be directed into specific Treasury funds.

Geographic scope

United States US

Taxonomy

Primary area

Sanctions

Operational domain

Compliance

Compliance frameworks

OFAC Sanctions

Topics

International Trade Energy

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OFAC Issues General Licenses for PdVSA Transactions

Summary

What changed

What to do next