March 16, 2026

New green lights for Venezuela: What do the latest U.S. general licenses authorize?

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

Key takeaways

Venezuela-related general licenses present opportunities for U.S. companies.

Companies must be aware of the limitations and conditions of each authorization.
Beginning late January 2026, the U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) issued several Venezuela-related general licenses expanding authorizations for trade and investment primarily in Venezuela's oil and gas sector. OFAC additionally updated its Venezuela-related frequently asked questions page to clarify key terms and compliance expectations. Our alert provides a high-level overview of the new general licenses and potential opportunities for U.S. businesses.

Overview of Venezuela-related general licenses

Since January 2026, OFAC has issued the following new and amended Venezuela-related general licenses (GLs). None of these GLs have an expiration date.

• GL 46 (January 29, 2026): Authorizing Certain Activities Involving Venezuelan-Origin Oil; subsequently replaced by GL 46A (February 10, 2026)
• GL 47 (February 3, 2026): Authorizing the Sale of U.S.-Origin Diluents to Venezuela
• GL 48 (February 10, 2026): Authorizing the Supply of Certain Items and Services to Venezuela
• GL 30B (February 10, 2026): Authorizing Certain Transactions Necessary to Port and Airport Operations
• GL 49 (February 13, 2026): Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela
• GL 50 (February 13, 2026): Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities; subsequently replaced by GL 50A (February 18, 2026)
• GL 51 (March 6, 2026): Authorizing Certain Activities Involving Venezuelan-Origin Gold

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

Below describes the specific activities authorized by each new General License, as well as explanations of the key associated Venezuela-related Frequently Asked Questions (FAQs) issued by OFAC related to the new GLs. These FAQs provide definitions for terms used in the GLs (such as “commercially reasonable terms,” “established U.S. entity,” and “Venezuelan-origin oil”), clarification on what is and is not authorized, and the types of transactions covered by the GLs.

GL 46 (now replaced and superseded in its entirety by 46A): Certain activities involving Venezuelan-origin oil

• GL 46/46A authorizes transactions otherwise prohibited by the Venezuela Sanctions Regulations (the VSR), including those involving the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (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.”
  • OFAC FAQ 1227 states that the activities authorized may include:
  • “[E]ngaging in commercial, legal, and technical discussions necessary to scope purchases of Venezuelan-origin oil, including with third-party legal, commercial, or due diligence consultants;
  • [C]onducting safety, environmental, and other relevant inspections, including site surveys;
  • [A]rranging logistics, security services, delivery points, and shipping preparation, including obtaining marine insurance and engaging with relevant port or maritime authorities of [GOV] or their personnel;
  • [C]onducting certain downstream activities, including the refining and resale of Venezuelan-origin oil;
  • [C]oordinating payment structures, including payments in the form of swaps of oil, diluents, or refined petroleum products, among others;
  • [M]aking required repairs and maintenance to pipeline, storage, or port infrastructure necessary to effectuate the loading of vessels; or
  • [T]he financing of related cargos or receivables.”
  • Additional authorized transactions include:
  • Chartering vessels, obtaining marine insurance and protection and indemnity coverage, and arranging port and terminal services, including with port authorities or terminal operators that are part of GOV.
  • OFAC FAQ 1226 defines “Venezuelan-origin oil” as “crude oil or petroleum products extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products.”
  • OFAC FAQ 1229 defines “established U.S. entity” as “any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025,” which is consistent with the definition provided in GL 46A.
• OFAC FAQ 1237 clarifies that GL 46A authorizes the “routine payment of local taxes, permits, and fees” to GOV or “its instrumentalities.” FAQ 1237 further explains that other types of payments, such as royalties, must be made into the Foreign Government Deposit Funds, as specified in Executive Order (EO) 14373, or another account as instructed by the U.S. Department of the Treasury. Additionally, OFAC FAQ 1239 explains that “to obtain payment account information for payments to the Foreign Government Deposit Funds…please contact DepositorInquiries@state.gov [] ” and be prepared to provide the relevant transaction details.
• GL 46/46A also permits commercially reasonable payments “in the forms of swaps of crude oil, diluents, or refined petroleum products.”
  • OFAC FAQ 1232 defines “commercially reasonable terms” as “terms that are consistent with prevailing market and industry standards for like or similar products produced by a company of similar size and scope, while taking into account characteristics such as quality, quantity, pricing, performance, and safety, among others.”
• Use of this GL comes with reporting obligations to the U.S. Department of State (State) and the U.S. Department of Energy (DoE).

GL 47: Sale of U.S.-origin diluents to Venezuela

• GL 47 authorizes all transactions prohibited by the VSR, including those involving GOV, PdVSA, or PdVSA entities, that are ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, marketing, delivery, or transportation of U.S.-origin diluents to Venezuela.
• OFAC FAQ 1240 clarifies that with respect to GL 47, “diluent means a light hydrocarbon liquid, such as natural gas condensate, naphtha, or light crude oil, that is added to heavy crude oil or bitumen to reduce its viscosity and density in order to transport, export, store, or process more easily.”
• Use of this GL comes with reporting obligations to State and DoE.

GL 48: Supply of certain items and services to Venezuela

• 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.
• OFAC FAQ 1237 clarifies that GL 48 authorizes the “routine payment of local taxes, permits, and fees” to GOV or “its instrumentalities.”
• OFAC FAQ 1241 provides examples of the transactions authorized by GL 48, including:
  • Insurance services for oil and gas operations;
  • Maintenance, refurbishment, or repair of items used for oil or gas exploration, development, or production activities;
  • Spare or replacement parts required to maintain oil or gas production activities;
  • Exploration and subsurface interpretation software;
  • Well stimulation products such as fracturing fluids; or
  • The processing of payments from the GOV or other authorized blocked persons for the underlying transactions.
• Use of this GL comes with reporting obligations to State and DoE.

GL 30B: Certain transactions necessary to port and airport operations

• GL 30B supersedes and replaces in its entirety GL 30A, dated February 2, 2021.
  • OFAC FAQ 1236 clarifies that GL 30B “removes the prohibition in GL 30A regarding transactions or activities related to the exportation or reexportation of diluents to Venezuela.”
• GL 30B authorizes all transactions and activities involving GOV that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela that would otherwise be prohibited by EO 13884, as incorporated into the VSR.
  • GL 30B also authorizes transactions that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela involving the Instituto Nacional de los Espacios Acuaticos (INEA), or any entity in which INEA owns 50 percent or more, directly or indirectly.

GL 49: Negotiations of and entry into contingent contracts for certain investment

• 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.
  • The authorization includes:
  • Contingent contracts to engage in new oil or gas exploration, development, or production activities in Venezuela, expansion of existing operations in Venezuela, and formation of new joint ventures or other entities in Venezuela related to the foregoing; and
  • Prefatory steps such as conducting commercial, legal, technical, safety, and environmental due diligence and assessments.
  • Contingent contracts “includes executory contracts, executory pro forma invoices, agreements in principle, executory offers capable of acceptance such as bids or proposals in response to public tenders, binding memoranda of understanding, or any other similar agreement.”
  • OFAC FAQ 1244 clarifies that OFAC will assess the specific license applications to perform any contingent contracts executed pursuant to GL 49 on a case-by-case basis that is consistent with U.S. foreign policy and national security priorities.
• Companies considering agreements under GL 49 (and GL 50A, discussed further below) should also evaluate whether the contemplated activities require separate authorizations or approvals under Venezuelan law, including as applicable under Venezuela’s revised Organic Hydrocarbons Law (the “Hydrocarbons Law Amendment”). The Hydrocarbons Law Amendment facilitates foreign investment into the Venezuelan economy by relaxing private companies’ ability to perform certain Primary Activities previously carried out by the National Executive or wholly-owned state companies or their affiliates.

GL 50A: Oil or gas sector operations in Venezuela of certain entities

• GL 50A authorizes all transactions prohibited by VSR, including those involving GOV, PdVSA, and PdVSA Entities, that are related to oil or gas sector operations in Venezuela for entities listed in the Annex of GL 50A and their subsidiaries, which as of February 18, 2026, include:
  • BP PLC;
  • Chevron Corporation;
  • Eni S.p.A.;
  • Établissements Maurel & Prom SA
  • Repsol S.A.; and
  • Shell PLC.
• OFAC FAQ 1242 describes the types of transactions authorized by GL 50A, including:
  • The lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of oil or gas from Venezuela, as well as the refining of such oil or gas;
  • The provision or receipt of goods, services, software, or technology related to oil or gas sector operations in Venezuela;
  • New investment in oil or gas sector operations in Venezuela, including expanding existing operations in Venezuela, engaging in new oil or gas exploration, production, or development activities in Venezuela, and forming new joint ventures or other entities in Venezuela related to the foregoing activities;
  • Engaging in prefatory steps for any of the foregoing activities, such as conducting commercial, legal, technical, safety, and environmental due diligence and assessments; and
  • The processing of payments related to any of the aforementioned activities.
• OFAC FAQ 1242 also confirms that “U.S. persons may enter into contracts with entities identified in the Annex of GL 50A that are ordinarily incident and necessary to transactions authorized by GL 50A.”
  • OFAC FAQ 1243 notes that any entities not identified in the Annex of GL 50A can rely on other authorizations to support the development of oil or gas projects in Venezuela, including by entering into contingent contracts related to transactions authorized by GLs 48 and 49.
• Use of this GL comes with reporting obligations to State and DoE.

GL 51: Certain activities involving Venezuelan-origin gold

• GL 51 authorizes all transactions prohibited by VSR, including those involving GOV, CVG Compania General de Mineria de Venezuela CA (Minerven) and 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, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin gold for importation into the United States, refining within the United States, or resale or exportation from the United States.
  • This authorization includes:
  • [C]ommercial, legal, technical, safety, and environmental due diligence and assessments ordinarily incident to the activity described above; and
  • [A]rranging shipping and logistics services, including:
    • [C]hartering vessels,
    • [A]rranging security services,
    • [O]btaining marine insurance and protection and indemnity (“P&I”) coverage, and
    • [A]rranging port and terminal services, including with port authorities or terminal operators that are part of the GOV.
• Use of this GL comes with reporting obligations to State and the U.S. Department of the Interior.

Next steps

The new GLs present opportunities for U.S. companies, but companies must be aware of the limitations and conditions of each authorization. Companies considering activity under these new authorizations from OFAC should conduct careful review prior to reliance on any GL.
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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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