March 20, 2026

OFAC Issues Venezuela-Related Sanctions Relief

Melissa Duffy, Carrie Schroll, Robert Slack Fenwick & West LLP + Follow Contact LinkedIn Facebook X Send Embed

Since March 1, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued multiple new measures relieving some of the sanctions on Venezuela as part of the ongoing thaw in the U.S. relationship with Venezuela. These measures primarily have taken the form of general licenses authorizing certain otherwise prohibited conduct (including oil-related activities in Venezuela), combined with published policy guidance and establishment of a new payments mechanism to enable authorized transactions to proceed. The general licenses have a tailored scope, authorizing U.S. persons operating in or considering engagement with Venezuela’s oil, petrochemical, and certain other industrial sectors. Companies looking to engage in dealings in Venezuela may be able to rely on a general license, although it is important to understand the limitations on the scope of authorized activities and requirements for contracting, payments, and reporting.

Overview of the New General Licenses

General License 52

On March 18, 2026, OFAC issued General License 52 (GL52), which authorizes otherwise prohibited transactions by an established U.S. entity with Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns, directly or indirectly, a 50% or greater interest (a PdVSA entity), subject to several limitations and exceptions. An “established U.S. entity” must be organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025. GL52 represents a significant expansion of the previously issued Venezuela-related general licenses, which had been more targeted to specific oil and gas activities. GL52 functionally unblocks the PdVSA entities for many types of transactions. Notably, GL52 also authorizes dealings with other sanctioned Government of Venezuela entities if necessary for authorized transactions with the PdVSA entities. However, this is not a general authorization to deal with the Government of Venezuela or its other state-owned enterprises.

GL52 imposes some limitations, including the following:

• Contracts for authorized transactions must be governed by U.S. laws and provide for dispute resolution in the United States.
• Payments to blocked persons, including the PdVSA entities, must be made into the Foreign Government Deposit Funds managed by the U.S. Treasury.
• No debt swaps, payments in digital currency or gold, or payment terms that are not commercially reasonable.
• Transactions otherwise prohibited by the Venezuela Sanctions Regulations (VSR) (31 CFR Part 591) are not authorized, such as those that relate to bonds and debt of the Government of Venezuela or the PdVSA entities, settlement or enforcement of liens or judgments related to those debts, and transfers of equity in the PdVSA entities.
• Transactions cannot involve other Specially Designated Nationals (SDNs), Russia, Cuba, Iran, or North Korea, or 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.
• Transactions cannot unblock blocked property or involve a blocked vessel. Any person who exports, reexports, or sells Venezuelan-origin oil or petrochemical products to persons outside the United States in transactions conducted under GL52 is subject to reporting requirements. Ten days after the first transaction and every ninety days after that, a report must be submitted to the State Department and Energy Department via email listing out the parties involved, the description of the transaction, and any taxes, fees, or payments provided to the Government of Venezuela.

General License 51

OFAC also recently issued General License 51 (GL51) authorizing prohibited transactions, including with the Government of Venezuela, CVG Compania General de Mineria de Venezuela CA (Minerven), or any entity in which Minerven owns, directly or indirectly, a 50% or greater interest, that are ordinarily incident and necessary to dealings in Venezuelan-origin gold for importation into the United States, refining in the United States, and resale or export from the United States. This represents a departure in scope from the majority of OFAC’s recent general licenses for Venezuela, in that it provides sanctions relief tailored to the gold industry, versus energy and petrochemicals.

As with GL52 and other general licenses issued in relation to Venezuela, GL51 imposes limitations, including the following:

• Contracts for authorized transactions must be governed by U.S. laws and provide for dispute resolution in the United States.
• Payments to blocked persons must be made into the Foreign Government Deposit Funds.
• Mining, exploration, production, or refining of gold in Venezuela or the formation of joint ventures or other entities in Venezuela to engage in such activities are not authorized.
• No debt swaps, payments in digital currency or gold, or payment terms that are not commercially reasonable.
• Transactions cannot involve other SDNs, Russia, Cuba, Iran, or North Korea, or 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.
• Transactions cannot unblock blocked property or involve a blocked vessel. Those who export, reexport, sell, resell, purchase, or supply Venezuelan-origin gold pursuant to GL51 must report to the Departments of State and Energy ten days after the first transaction and every 30 days thereafter. The reports must describe the parties; supply chain diligence showing chain of custody of the gold; quantities, descriptions, and purchase prices of the gold; dates of transactions; and taxes, fees, or other payments to the Government of Venezuela.

Revised General Licenses 46, 48, 49, and 50

On March 13, OFAC also broadened prior general licenses, issuing General Licenses 46B, 48A, and 49A to authorize not only activity related to oil and gas, but also to cover petrochemical products and electricity sector operations in Venezuela. The updated general licenses each include an annex that lists chemicals that fall within the term “petrochemical products” and are within scope of the authorizations.

On February 18, OFAC separately updated General License 50A (GL50A) to add more entities to the list of authorized transaction partners in the annex of that authorization. GL50A broadly authorizes transactions otherwise prohibited by the VSR that relate specifically to oil or gas sector operations of entities listed in the annex.

New Payments Mechanism

Executive Order 14373 established the Foreign Government Deposit Funds into which payments to sanctioned Venezuelan parties must be made as dictated in the general licenses described above. Executive Order 14373 defines the Foreign Government Deposit Funds as “funds paid to or held by the United States Government in designated United States Department of the Treasury accounts or funds on behalf of the Government of Venezuela or its agencies or instrumentalities, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A., that are derived from either the sale of natural resources from, or the sale of diluents to, the Government of Venezuela or its agencies or instrumentalities.” The U.S. government is taking an active role in disbursing these funds to the Government of Venezuela in a custodial arrangement. Companies acting under a general license will need to contact DepositorInquiries@state.gov to understand how payments should be made into the appropriate Foreign Government Deposit Funds accounts.

Published Guidance

OFAC has published multiple FAQs providing guidance on the general licenses for Venezuela, located at OFAC’s Venezuela Sanctions FAQs page starting at FAQ 1226. Topics include interpretations of defined terms, examples of activities that are in and out of scope of the general licenses, and explanations on how to make authorized payments to the Foreign Deposit Funds.

Considerations for Companies Conducting Transactions in Venezuela

Each of OFAC’s general licenses in this latest round covers a specific scope, and in some ways they can overlap. For example, GL52 broadly authorizes dealings with PdVSA; several other general licenses would similarly authorize dealings with PdVSA if related to the oil and gas sectors or petrochemical products. However, General Licenses 46 through 50 go beyond authorizing dealings with PdVSA to allow transactions that are otherwise prohibited by the VSR for certain sectors. Companies should closely review the different general licenses, consider whether proposed activity is authorized under one or more of the authorizations, and determine the scope and limitation of any available authorization.

Companies that decide to move forward with a transaction in Venezuela that is authorized under an OFAC general license should consider implementing compliance guardrails to ensure:

• Transaction scope and structure are clearly authorized by the terms of the general license and comply with limitations imposed by license conditions
• Agreement and payment terms align with the general licenses’ requirements
• Prohibited parties and countries are not involved
• Reporting obligations are met
• Dealings can be quickly terminated if authorizations are revoked or change The sanctions landscape for Venezuela continues to evolve and more general licenses could be forthcoming.

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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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