OFAC Amended Seven Venezuela General Licenses and Standardized Their Contractual Framework

On June 10, 2026, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury simultaneously amended seven General Licenses under the Venezuela Sanctions Regulations (31 CFR part 591) ("VSR"): GLs 46C, 47A, 48B, 50B, 51B, 52A, and 54A. All seven were signed the same day and replace and supersede their prior versions in their entirety. The amendment does not expand sectors or add authorized entities: It modifies —with identical language across the series— the contractual conditions that every transaction conducted under these licenses must satisfy.

The amendment belongs to the regulatory sequence OFAC has been deploying throughout 2026, which we have analyzed in previous installments. The four March licenses (GL 46B, GL 48A, GL 49A, and GL 52) built the sectoral perimeter of the new framework —hydrocarbons, petrochemicals, electricity, minerals (see José P. Barnola Jr., Four New OFAC General Licenses: The New Framework for Doing Business with Venezuela)—; the two April licenses enabled the negotiation of contingent contracts and the payment channels (see José P. Barnola Jr. and Raúl Sancristóbal, Two New OFAC General Licenses: Contingent Contracts and Financial Services with Venezuela); the May license opened the professional advisory layer for an eventual debt restructuring (see José P. Barnola Jr. and Raúl Sancristóbal, OFAC's New General License: Advisory Services for a Potential Restructuring of Venezuelan Debt). The June round does something different: It does not open a new layer — it standardizes the contractual terms of everything that came before.

The Seven Amended Licenses

The affected licenses cover the transactional core of the regime: (i) GL 46C (purchase and transport of Venezuelan-origin oil and petrochemical products by established U.S. entities), (ii) GL 47A (sale of U.S.-origin diluents to Venezuela), (iii) GL 48B (supply of goods, technology, and services for the hydrocarbons, petrochemicals, and electricity sectors), (iv) GL 50B (oil and gas operations of the six entities listed in its Annex: BP, Chevron, Eni, Maurel & Prom, Repsol, and Shell), (v) GL 51B (export and purchase of Venezuelan-origin minerals, including gold, involving Minerven), (vi) GL 52A (transactions by U.S. entities involving PdVSA), and (vii) GL 54A (supply of goods and services for minerals operations). The contingent-contract licenses (GLs 49A and 55) and the April and May licenses (GLs 56, 57, and 58) were not amended. The Annexes —authorized entities and product lists— did not change either.

The Three Changes (Identical Across the Series)

1. From law that "governs" the contract to terms that are "construed and interpreted" under U.S. law

The prior versions required every contract with the Government of Venezuela, PdVSA, or PdVSA Entities to specify that "the laws of the United States or any jurisdiction within the United States govern the contract." The new text requires that "the terms of the contract be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States." The change runs deeper than it appears: A governing-law clause submits the validity, performance, and effects of the entire contract to one legal system; an interpretation clause only fixes the standard for construing its terms. In practice, this means the contract no longer needs to be "governed" wholesale by U.S. law — it suffices to agree that its terms are construed under New York, Texas, or Delaware law, leaving room for other aspects of the relationship to be governed by other legal systems.

2. Dispute resolution forums: From the United States only to four jurisdictions

The prior versions required all dispute resolution under the contract to occur in the United States. The new text allows proceedings to occur "in the United States, the United Kingdom, France, or Singapore." The selection does not appear casual: London, Paris, and Singapore are the seats of the three arbitral institutions where disputes with sovereign counterparties and state-owned enterprises are typically seated (the London Court of International Arbitration, the International Chamber of Commerce and the Singapore International Arbitration Centre, respectively), and they are the venues where the European oil companies listed in the GL 50B Annex have established arbitration practice. The license, it bears noting, names jurisdictions — not arbitral institutions or specific rules; the choice of seat, institution, and rules remains with the parties.

3. Express recognition of Venezuelan regulatory law

Each license incorporates a new Note with identical language: The U.S.-law interpretation requirement "permits the inclusion of contract terms that recognize that certain aspects of the underlying activity in Venezuela may be subject to applicable Venezuelan law and regulations." The aspects the licenses expressly allow to be subject to Venezuelan law are the following (all regulatory/public in nature, not contractual):

• Venezuela's sovereign regulatory authority — the State's exercise of public powers.
• Administrative permits and licenses — governmental authorizations required to operate.
• Concessions — the enabling titles granted by the Venezuelan State.
• Labor law — employment relationships with employees in Venezuela.
• Environmental law — environmental compliance obligations in Venezuelan territory.
• Occupational health and safety — health, safety, and environmental regulations applicable in Venezuela.
• Other mandatory regulatory requirements — any other imperative rule of Venezuelan public law (e.g., tax rules).

OFAC expressly acknowledges what any transactional lawyer with a Venezuela practice already knew: The physical operation in-country —permits, concessions, labor and environmental regimes— can only be governed by Venezuelan law. The prior standard, by requiring U.S. law to govern the entire contract, created a drafting tension that was difficult to resolve.

What It Means in Practice

For those drafting contracts under these licenses: The viable model as of June 10 is an interpretation clause under the law of a U.S. state (on a textual reading, a generic reference to federal law may not suffice), an express carve-out for Venezuelan law on regulatory aspects, and a dispute resolution clause seated in any of the four permitted jurisdictions. We estimate that contracts already executed under the prior standard (U.S. law plus an exclusive U.S. forum) also satisfy the new one — the U.S. forum remains permitted and the old clause is more demanding, not less. It is nonetheless advisable to review template clauses before the next closing, particularly any reference to "the laws of the United States" standing alone, which the new text replaced with the law "of a state or other jurisdiction within" the United States.

For non-U.S. counterparties: The European oil companies listed in the GL 50B Annex and the traders operating under GLs 46C and 47A are no longer required to litigate or arbitrate in the United States. They may agree to litigate or arbitrate in London, Paris, or Singapore.

For the Venezuelan counterparty: The recognition of Venezuelan regulatory law gives express cover to the negotiating position of the State and its public enterprises on permits, concessions, and labor and environmental regimes. As far as our review reaches, this is the first time this language appears in the Venezuela program licenses.

What Did Not Change

The rest of the scaffolding remains intact. Payments to blocked persons —except local taxes, permits, and fees— must still be channeled into the Foreign Government Deposit Funds created by Executive Order 14373. The exclusions for Russia, Iran, North Korea, Cuba, and China remain. The reporting obligations to the Departments of State and Energy (or Interior, for the mining licenses) remain unchanged: A first report ten days after the first transaction and every ninety days thereafter — every thirty days, with chain-of-custody documentation, under GL 51B. The prohibition on forming new joint ventures in Venezuela under GLs 48B, 51B, and 54A remains in force. And the entire regime can be revoked, modified, or restricted by OFAC at any time.

The Strategic Takeaway

Two signals emerge from the June round. First: Requiring an exclusive U.S. forum and U.S. law governing the entire contract was unworkable for European and Asian counterparties; the relaxation suggests OFAC is incorporating feedback from operators already working under the framework. Second: Recognizing that activity in Venezuela is subject to Venezuelan law is a step —technical, but significant— toward contracts that are enforceable in the real world and not only before U.S. courts or arbitral tribunals.

None of this amounts to a lifting of sanctions. The framework remains a conditioned, monitored administration of access to the Venezuelan market, and each authorization keeps its exclusions and reporting requirements. But the direction is consistent with what the March-to-May sequence already showed: A regime that is becoming more sophisticated, more standardized, and ready to operate at greater scale.

For any company operating or evaluating operations under these licenses, the advice is invariable: Obtain specialized legal counsel before closing the next contract. The contractual conditions changed on June 10 for all seven licenses at once — and the responsibility for complying with them rests entirely with whoever uses them.