Two New OFAC General Licenses: Contingent Contracts and Financial Services with Venezuela

On April 14, 2026, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury issued two new General Licenses under the Venezuela Sanctions Regulations (31 CFR Part 591): General License No. 56 ("GL 56"), authorizing the negotiation of contingent commercial contracts with the Government of Venezuela, and General License No. 57 ("GL 57"), authorizing financial services transactions with four major Venezuelan state banks and with Government of Venezuela individuals not individually listed on OFAC's Specially Designated Nationals and Blocked Persons List ("SDN List").

These licenses complement—and in certain respects complete—the framework opened by the four general licenses issued in March 2026 (GL 46B, GL 48A, GL 49A, and GL 52; see our analysis of the Four New OFAC General Licenses: The New Framework for Doing Business with Venezuela). While those licenses focused on specific sectors—hydrocarbons, petrochemicals, electricity—and on transactions with Petróleos de Venezuela, S.A. ("PdVSA") and its subsidiaries, GL 56 and GL 57 address two bottlenecks that remained unresolved: the legal ability to negotiate contracts with the Government of Venezuela as such—beyond PdVSA—and access to Venezuela's state banking system. Without these two pieces, many of the March authorizations were difficult to implement in practice.

Under the Venezuela Sanctions Regulations, General Licenses are broad authorizations that allow U.S. persons and entities to engage in certain transactions without needing to apply for a specific license on a case-by-case basis. Their scope is precise: what is not expressly authorized remains prohibited.

GL 56: Authorization to Negotiate with the Government of Venezuela

GL 56 authorizes all transactions prohibited by Executive Order ("EO") 13884 that are ordinarily incident and necessary to engage in commercial-related negotiations of contingent contracts with the Government of Venezuela. The defining feature of this license is contingency: any contract entered into under this license must be made expressly contingent, both as to its entry into force and its performance, upon a separate and specific OFAC authorization.

To understand the true scope of GL 56, it is essential to define what the license means by "Government of Venezuela" and what types of agreements qualify as "contingent contracts":

• "Government of Venezuela" — The term has the meaning set forth in section 6(d) of EO 13884 and encompasses: the state and Government of Venezuela; any political subdivision, agency, or instrumentality thereof; any person owned or controlled, directly or indirectly, by the foregoing; and any person who has acted or purported to act, directly or indirectly, for or on behalf of the foregoing. The definition is deliberately broad: it is not limited to executive ministries, but extends to state-owned enterprises, autonomous agencies, state funds, mixed enterprises under government control, and any entity or individual operating as an agent or representative of the Venezuelan government. In practice, this means that a U.S. person negotiating a contract with the Ministry of the Popular Power of Hydrocarbons, with the Venezuelan Social Security Institute, with PEQUIVEN—or with any contractor acting as a government agent—is interacting with the "Government of Venezuela" within the meaning of EO 13884.
• "Contingent contracts" — GL 56 adopts a broad definition that includes: executory contracts; executory pro forma invoices; agreements in principle; executory offers capable of acceptance, such as bids or proposals submitted in response to public tenders; binding memoranda of understanding; or any other similar agreement. The breadth of the definition is intentional: OFAC recognizes that the negotiation process involves multiple stages and documents, not all of which constitute a contract in the strict legal sense. By including binding MOUs and public tender proposals, the license allows persons to actively participate in Venezuelan government contracting processes without each step requiring an individual license.

What GL 56 Enables in Practice

Prior to GL 56, any direct negotiation with the Government of Venezuela—including the preparation of a bid or participation in a preliminary meeting—could constitute a prohibited transaction under EO 13884. U.S. companies with an interest in Venezuela faced a dilemma: apply for a specific license (a process that can take months) or assume the risk of violating sanctions. GL 56 eliminates that dilemma for the pre-contractual phase.

Specifically, GL 56 now allows a U.S. person to:

• Participate in Venezuelan public tenders and submit executable proposals.
• Sign agreements in principle, binding MOUs, and letters of intent with Venezuelan government counterparts.
• Enter into executory contracts with the Government of Venezuela, provided they contain an express contingency clause conditioning their performance on OFAC authorization.
• Conduct legal, commercial, and technical due diligence with government counterparts.
• Negotiate and review contract terms with ministries, state enterprises, or other Government of Venezuela entities.

The limit is clear: the actual performance of the contract—beginning operations, delivering goods, providing services—will still require a specific and additional OFAC authorization. GL 56 is not an execution license; it is a preparation and negotiation license.

GL 57: Opening Venezuela's State Banking System

GL 57 authorizes all transactions prohibited by the Venezuela Sanctions Regulations ("VSR") (see 31 CFR Part 591) that are ordinarily incident and necessary to the provision, exportation, or reexportation—directly or indirectly—of financial services to, from, or for the benefit of the following persons:

1. Banco Central de Venezuela.
2. Banco de Venezuela, S.A. Banco Universal.
3. Banco Digital de los Trabajadores Banco Universal, C.A.
4. Banco del Tesoro, C.A. Banco Universal.
5. Any entity in which one or more of the above persons own, directly or indirectly—individually or in the aggregate—a 50% or greater interest.
6. Any individual whose property and interests in property are blocked solely under EO 13884 because that individual meets the definition of "Government of Venezuela"—including current employees thereof—excluding any individual individually listed on OFAC's SDN List.

GL 57 also authorizes all transactions with the Government of Venezuela that are necessary for the financial services activities set forth above.

The Four Banks and Their Significance

The selection of the four authorized banks is not arbitrary. All are Venezuelan state institutions and collectively represent a substantial portion of the country's formal banking activity:

• Banco Central de Venezuela: Venezuela's monetary authority, responsible for exchange rate policy, international reserves, and monetary issuance. Its authorization is essential for any U.S. dollar correspondent banking operation, foreign exchange settlement, and for channeling the financial flows generated under the March licenses.
• Banco de Venezuela: the largest state-owned commercial bank in Venezuela, with a broad branch network and corporate and retail clients. It is the primary payment channel for the public sector and one of the most significant banking institutions in the country.
• Banco Digital de los Trabajadores: a worker-focused digital bank that is key for payroll processing and employment benefits payments.
• Banco del Tesoro: the Venezuelan Public Treasury's bank, handling state treasury operations, government vendor payments, and other executive branch fiscal operations.

The practical significance of this authorization can hardly be overstated. Until April 14, 2026, these four institutions were blocked under EO 13884 as part of the "Government of Venezuela." That meant any U.S. bank attempting to provide financial services to these institutions—even routine correspondent banking operations—risked violating sanctions. GL 57 resolves that bottleneck and opens the payment channels that make authorized commerce with Venezuela viable.

The Government Employee Carve-In

GL 57 includes a provision relevant to day-to-day operations: it also authorizes financial services for any individual whose property is blocked solely because they are an employee of the Venezuelan government within the meaning of EO 13884, provided that individual is not individually listed on the SDN List. This provision addresses a common situation in sanctions law: many Venezuelan officials are "blocked" as a category (for working for the government) but have not been individually designated as SDN for illicit conduct. GL 57 opens financial services access for this group.

The Breadth of "Financial Services"

Note 1 to GL 57 contains one of the most detailed definitions in the new regime. "Financial services" includes, among others: maintaining, operating, or closing of accounts; loans; transfers of funds; banking services; money transfer services; collection; acceptance of deposits; insurance; guarantees; cash withdrawals; check services; ACH transfers and wire transfers; debit card, prepaid card, and ATM transactions; issuance and use of payment cards and digital wallets; currency exchange; U.S. dollar-denominated banking, payment, and correspondent account services; collection, forwarding, processing, or receipt of funds and remittances; processing of salary, pension, payroll, and other employment benefits; transfers through mobile money, mobile wallets, digital bank accounts, credit cards, debit cards, online payments, or other digital technology; related safety, fraud-prevention, screening, authentication, and cybersecurity services and technologies; investments; securities; and commodity futures or options.

The list is exhaustive and covers virtually any service a modern financial institution would provide. Its breadth reflects a deliberate OFAC intention to clear all possible obstacles to financial flows within the authorized perimeter.

The Safe Harbor for U.S. Financial Institutions

Note 2 to GL 57 is a high-value practical provision for banks and financial institutions. It provides that a U.S. financial institution processing transactions authorized under the license may rely on the originator or beneficiary of a funds transfer regarding compliance with GL 57, provided the processing institution does not know—or have reason to know—that the transaction is not in compliance with its terms.

In the real world of sanctions, this clause is extremely valuable. Historically, U.S. correspondent banks have engaged in aggressive overcompliance with respect to Venezuela, blocking transactions even when they may have been lawful under existing licenses. Note 2 gives them a solid compliance basis for processing these transactions without bearing the burden of verifying each underlying transaction, as long as the originator or beneficiary declares that the operation is covered by GL 57.

Other Compliance Obligations

Note 3 to GL 57 clarifies that nothing in the license relieves any person from compliance with other U.S. laws, particularly the Bank Secrecy Act (31 U.S.C. §5311 et seq.), the USA PATRIOT Act (Pub. L. 107-56), and FinCEN regulations. This reminder is important: having OFAC authorization does not mean exemption from anti-money laundering and counter-terrorism financing (AML/CFT) obligations. Suspicious activity reports (SARs), customer due diligence (CDD) duties, and internal compliance programs continue to apply in full.

Key Exclusions and Conditions

GL 56 exclusions

1. Debt, bonds, and equity (EO 13808 and 13835): GL 56 does not authorize transactions related to bonds or other debt instruments of the Government of Venezuela or PdVSA prohibited by EO 13808—including their settlement—nor transactions related to the sale, transfer, assignment, or pledge as collateral of equity interests in PdVSA or entities in which the Government of Venezuela holds 50% or more, under EO 13835. Venezuelan sovereign debt issues and claims over PdVSA equity assets remain outside the scope of this license.
2. Unreasonable payment terms, cryptocurrencies, and metals: Contracts with payment terms that are not commercially reasonable, debt swaps, payments in gold, or payments in digital currencies, tokens, or cryptocurrencies issued by, for, or on behalf of the Government of Venezuela—including the Petro—are not authorized.
3. Settlement agreements and enforcement: GL 56 does not authorize the entry into settlement agreements or the enforcement of liens, judgments, arbitral awards, decrees, or other orders involving the transfer or alteration of blocked property under the VSR. This exclusion is particularly relevant for companies with pending arbitration claims against Venezuela or PdVSA.
4. Nexus with Russia, Iran, North Korea, and Cuba: Transactions involving persons located in those countries, or entities owned or controlled by or in a joint venture with such persons, are excluded.
5. Nexus with China: GL 56 excludes transactions involving Venezuelan or U.S. entities that are directly or indirectly owned, controlled by, or in a joint venture with persons located in or organized under the laws of the People's Republic of China. This exclusion has broad reach and requires thorough due diligence: given that numerous Venezuelan companies—including mixed enterprises in the energy sector—have Chinese participation (CNPC, CNOOC, COSCO, among others), the counterparty's ownership chain must be carefully examined.
6. SDN List: Transactions with any individual or entity on OFAC's SDN List, or entities in which SDN-listed persons own 50% or more, are not authorized.
7. Unblocking of property: GL 56 does not authorize the unblocking of any property blocked pursuant to 31 CFR Chapter V.

GL 57 exclusions

GL 57's exclusions are more concise: (1) no unblocking of property blocked under any part of 31 CFR Chapter V; and (2) no transactions otherwise prohibited by the VSR, unless separately authorized. This second exclusion underlines the nature of GL 57: it is a broad license for financial services to the four designated banks and to government personnel, but it is not a general-purpose license.

The Strategic Takeaway

OFAC Sanctions · Venezuela · April 2026

GL 56 and GL 57: The New Framework for Operating in Venezuela

Two licenses that unblock authorized trade with Venezuela.

	GL 56	GL 57
Purpose	Negotiate contracts with the Government of Venezuela	Financial services with four state-owned banks
Legal basis	Executive Order 13884	Venezuela Sanctions Regulations · 31 CFR Part 591
Scope	Any Government of Venezuela entity	BCV, Banco de Venezuela, BDT, Banco del Tesoro
What it enables	Pre-contractual phase and negotiation	Payments, correspondent banking, financial flows
Key limit	Does not cover contract performance	Not a general-purpose license

Ágora Abogados S.C. · Compliance & Sanctionsagoralatam.com

GL 56 and GL 57 complete the architecture of the new Venezuela engagement framework designed by Washington in the first quarter of 2026. To understand them in perspective, it is helpful to see how they fit with the March licenses:

The March licenses built the perimeter of what can be done:

• GL 49A: Negotiate and invest in energy and petrochemicals with PdVSA entities.
• GL 48A: Supply goods and services to the hydrocarbons and electricity sectors.
• GL 46B: Purchase, transport, and commercialize Venezuelan oil into the U.S. market.
• GL 52: Enter into any commercial transaction with PdVSA and its entities.

The April licenses built the infrastructure to make it possible:

• GL 56: Negotiate the necessary contracts with any Government of Venezuela entity.
• GL 57: Channel payments through Venezuela's state banking system.

GL 56 as a negotiation enabler: GL 49A (March) already allowed for the negotiation of contingent contracts in the energy sector with respect to EO 13850, which applies specifically to PdVSA. GL 56 complements this by covering EO 13884 and extending negotiation authority to all "Government of Venezuela" entities in the broad sense. This is crucial for companies that interact not only with PdVSA but with ministries, PDVSA Gas Comunal, PEQUIVEN, the Venezuelan Social Security Institute, BANDES, or other Venezuelan state entities. The negotiation space expands considerably.

GL 57 as a payment enabler: The Venezuelan banking system problem was not a minor one. Many of the financial flows authorized by the March licenses had nowhere to go in the Venezuelan banking system because the main state institutions were blocked. With GL 57, U.S. banks and financial institutions can now operate with the Banco Central de Venezuela, Banco de Venezuela, Banco Digital de los Trabajadores, and Banco del Tesoro within the financial services perimeter defined by the license. This is what makes it possible for payments associated with trade authorized under the March licenses to actually be processed.

The China factor: The Chinese exclusion in GL 56 deserves special attention from any company considering operations under this framework. Venezuela has deep economic and financial ties with China: oil-for-debt agreements, construction contracts, mixed enterprises in the energy sector with CNPC and CNOOC, and loans from the China Development Bank. Any U.S. entity must conduct thorough due diligence on the ownership structure of its Venezuelan counterpart to verify there is no Chinese nexus that would invalidate the transaction under GL 56.

What remains unauthorized: The architecture of the new regime deliberately leaves some doors closed. Execution of contracts with the Government of Venezuela still requires a specific OFAC license. Transactions related to Venezuelan sovereign debt and claims over PdVSA equity remain prohibited. And the entire regime can be revoked, modified, or restricted by OFAC at any time.

Taken together, the six general licenses issued between March and April 2026 do not represent a lifting of sanctions: they represent a more sophisticated administration of them. The requirements that contracts be governed by U.S. law, that disputes be resolved in the United States, and that payments flow through the Foreign Government Deposit Funds (for the March licenses) and through banks with U.S. correspondent access (for GL 57) are mechanisms of control and visibility over the flows generated under these licenses. Washington wants trade with Venezuela to flow—under certain conditions—but it also wants to know exactly what flows, how much, and to retain the ability to shut it down if conditions change. GL 56 and GL 57 reinforce that logic: they enable the negotiation phase and the payment channels, but within a monitored system.

For any individual or entity evaluating operations under this new framework, the advice is invariable: obtain specialized legal counsel before executing any transaction. General licenses are broad, but their exceptions and conditions are precise—and the responsibility for compliance rests entirely with whoever uses them. Our Compliance & Sanctions practice advises U.S. and foreign clients on how to operate within the perimeter set by OFAC.