Four New OFAC General Licenses: The New Framework for Doing Business with Venezuela

Four New OFAC General Licenses: The New Framework for Doing Business with Venezuela

The week of March 13–18, 2026, marked a significant shift in the U.S. sanctions regime on Venezuela. The Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury issued four General Licenses that together establish the new framework under which U.S. entities may operate with Venezuela and with Petróleos de Venezuela, S.A. ("PdVSA"): three sector-specific licenses on March 13 -GL 46B, 48A, and 49A- and a fourth, broader license on March 18 -GL 52- signed by Bradley T. Smith, OFAC Director.

Under the Venezuela Sanctions Regulations (31 CFR Part 591), 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.

The three sectoral licenses in brief (GL 46B, 48A, and 49A)

• General License No. 46B - Authorizes established U.S. entities (organized under the laws of the US or any jurisdiction within the US on or before January 29, 2025) to purchase, transport, refine, and trade Venezuelan-origin crude oil and petrochemical products for importation into the U.S. market. It also covers related logistics services: vessel chartering, marine insurance, port operations, and swaps of crude oil or refined products.
• General License No. 48A - Allows the supply to Venezuela of goods, technology, software, and services for the exploration, production, and maintenance of the hydrocarbons and electricity sectors. In general terms, a U.S. company may sell equipment, provide technical services, or repair facilities in Venezuela under this license.
• General License No. 49A - The most strategic of the three: it authorizes the negotiation and entry into contingent contracts for new investments in Venezuela in oil, gas, petrochemicals, and electricity, including the formation of new joint ventures and the conduct of legal, technical, environmental, and commercial due diligence. Actual performance of those contracts requires a separate, specific OFAC authorization.

GL 52: A broader - and more demanding - authorization on PdVSA and its subsidiaries

GL 46B, 48A, and 49A are sector-specific licenses: their scope is oil, gas, petrochemicals, and electricity. GL 52 is materially broader. It is not limited to any particular sector or type of transaction: it authorizes all transactions prohibited by Executive Orders ("EO") 13884 and 13850 involving PdVSA or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, "PdVSA Entities"), regardless of sector or activity. An established U.S. entity may, in principle, enter into any commercial arrangement with PdVSA or its subsidiaries, well beyond the energy sector.

• Authorizes established U.S. entities to engage in all transactions prohibited by EO 13884 and EO 13850 involving PdVSA or PdVSA Entities.
• Also authorizes all transactions with the Government of Venezuela that are necessary for the activities described above.

Key conditions shared by all licenses

• Contracts with the Government of Venezuela, PdVSA, or PdVSA Entities must be governed by U.S. law, with dispute resolution in the United States.
• Monetary payments to blocked persons -other than local taxes, permits, or fees- must be channeled into the Foreign Government Deposit Funds established by Executive Order 14373 of January 9, 2026, or into any other account instructed by the U.S. Department of the Treasury. This mechanism ensures that payments to PdVSA remain under U.S. government oversight.
• None of the licenses cover transactions involving persons or entities linked to Russia, Iran, North Korea, Cuba, or China. The China exclusion is particularly broad under GL 48A; GL 52 extends it to Venezuelan or U.S. entities that are controlled by, or in a joint venture with, Chinese persons.
• Payments in cryptocurrency (including the Petro), debt swaps, gold payments, and transactions involving blocked vessels or assets are not authorized.
• Parties exporting Venezuelan oil to third countries (GL 46B, GL 52) or supplying goods/services to Venezuela (GL 48A) must report each transaction to the State Department ([email protected]) and the Department of Energy ([email protected]) within 10 days of the first transaction, and every 90 days thereafter.

What GL 52 does not authorize

GL 52 expressly excludes the following transactions:

• Transactions related to bonds and certain debt of the Government of Venezuela or PdVSA prohibited by EO 13808 (including debt settlement); and transactions related to the sale, transfer, assignment, or pledging of equity interests in PdVSA, PdVSA Entities, or any entity in which the Government of Venezuela holds 50% or more, as prohibited by EO 13835.
• Entering into settlement agreements or enforcing any lien, judgment, arbitral award, decree, or other order involving a transfer or alteration of property belonging to blocked persons, including PdVSA or PdVSA Entities.
• Transactions with any individual or entity on OFAC's Specially Designated Nationals and Blocked Persons (SDN) List - with the exception of PdVSA itself and PdVSA Entities.
• Unblocking any property blocked under the Venezuela Sanctions Regulations, or transactions involving a blocked vessel.

The strategic takeaway

The three sectoral licenses form an integrated system: GL 49A enables the negotiation and structuring of investments; GL 48A allows for the operation and maintenance of facilities; and GL 46B closes the loop by authorizing the commercialization of the product into the U.S. market. This is a framework of selective re-engagement with Venezuela's energy sector -on strict terms set by Washington, including the routing of financial flows through Treasury-controlled funds.

GL 52 does not replace that sectoral framework: it complements it with a horizontal authorization. PdVSA and its Entities cover a broad universe: Petroquímica de Venezuela (Pequiven), maritime shipping subsidiaries, mixed enterprises, and other entities in which PdVSA holds a majority stake. GL 52 authorizes transactions across that entire universe -without sector limitations- provided the counterpart is an established U.S. entity, contracts are governed by U.S. law, and payments flow through Treasury-controlled mechanisms.

The conditions built into all four licenses follow a clear logic: Washington has not lifted sanctions -it has administered them. The Foreign Government Deposit Funds requirement, the mandatory U.S. law and dispute resolution clauses, and the exclusion of adversarial nations are oversight mechanisms over any flows generated under the licenses. Any company operating under this regime must understand that it is doing so within a supervised framework, not outside the sanctions.