Unpacking the Recent Changes to the Venezuela Sanctions Program

At a Glance

• Since the January 3, 2026, capture of former Venezuelan President Nicolás Maduro, the United States has significantly eased prohibitions under the Venezuela-related sanctions program, primarily focused on lifting certain sanctions on the Venezuelan oil and gas sector, including a broad general license for certain transactions involving Petróleos de Venezuela, S.A. (PdVSA).
• On January 9, 2026, President Trump issued Executive Order (EO) 14373, which created the Foreign Government Deposit Funds — the vehicle through which funds from the US sale of Venezuelan oil will be deposited, to be held in custody by the United States.
• The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued several new and amended Venezuela-related general licenses, including authorizations to promote trade and investment in Venezuela’s oil, gas, and electricity sectors. Despite the easing of certain restrictions on trade and investment in Venezuela and certain transactions involving PdVSA, US persons remain prohibited from engaging in most transactions with the Government of Venezuela (GOV) and Venezuelan government officials subject to blocking sanctions.

On January 3, 2026, President Trump announced the capture of former Venezuelan President Nicolás Maduro, which was the result of a US operation — Operation Resolve. Since President Maduro’s capture, the United States has altered its approach to Venezuelan sanctions through the issuance of new general licenses and guidance.

Key Takeaways

1. The Venezuela-related sanctions legal framework remains in place.

   Unlike the Syria sanctions program, President Trump has not revoked any Venezuela-related executive orders. Rather, OFAC loosened sanctions on Venezuela through various general licenses (GLs), which can quickly be rescinded or amended. As such, companies conducting transactions under the GLs, including transactions with PdVSA under Venezuela GL No. 52, should ensure they have appropriate safeguards in place, such as contractual protections, to allow them to quickly exit out of or adjust such transactions in the event of a snapback of sanctions.

2. Certain of the new Venezuela GLs contain reporting requirements to the US government.

   Certain transactions under GLs 46B, 47, 48A, 50A, 51, and 52 contain reporting requirements to the US Department of State, the US Department of Energy, and/or the US Department of the Interior. Companies operating under these GLs should be mindful of these reporting requirements and ensure their sanctions compliance programs and due diligence practices are up to date in the event that OFAC or other agencies have follow-up questions about transactions reported and conducted under the GLs.

3. The new GLs contain various conditions and restrictions that may warrant new compliance procedures.

   The new GLs contain various conditions and restrictions, including certain GLs not authorizing transactions with blocked vessels. Companies considering the use of these GLs should consider implementing written compliance procedures; ensure that relevant personnel are trained on the scope of the authorizations, conditions, and restrictions; and screen all parties to the transactions to ensure compliance with the GLs.

Background

During his first term, President Trump issued EOs 13808 (August 2017) and 13835 (May 2018) prohibiting certain dealings in new debt, bonds, or other financial transactions involving the GOV and PdVSA. In November 2018, President Trump issued EO 13850, which authorizes OFAC to impose blocking sanctions on individuals or entities that operate in designated sectors of the Venezuelan economy (i.e., gold, oil, financial services, and defense security) or who engage in transactions involving deceptive practices or corruption and the Maduro government. Significant designations on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) under this EO include: (i) the January 2019 designation of PdVSA, a Venezuela state-owned oil company; (ii) the March 2019 designation of CVG Compañía General de Minería de Venezuela CA (Minerven), the state-owned metals mining company; and (iii), the April 2019 designation of Banco Central de Venezuela (i.e., the Central Bank of Venezuela).

In August 2019, President Trump issued EO 13884, which blocks all property and interests in property of the GOV. The EO essentially prohibits US persons from transacting with the GOV absent an OFAC license or exemption.

As further described below, following the capture of President Maduro, OFAC issued a series of general licenses easing certain restrictions described above by authorizing: (i) certain activities involving Venezuelan-origin oil or petrochemical products; (ii) the sale or supply of certain items and services to Venezuela (e.g., sale of US-origin diluents); (iii) negotiations of and entry into contingent contracts for certain investments in Venezuela; (iv) transactions related to oil or gas sector operations in Venezuela of certain entities; (v) authorizing certain activities involving Venezuelan-origin gold; and (vi) certain transactions involving PdVSA.

The majority of the GLs include conditions that: (i) any contract for authorized transactions specify that the laws of the United States or any jurisdiction within the United States govern the contract and that any dispute resolution under the contract occur in the United States; and/or (ii) any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds or any other account as instructed by the US Treasury Department.

The majority of the GLs also do not authorize any transaction involving: (i) payment terms that are commercially unreasonable (e.g., debt swaps, payments in gold, denominated in digital currency, digital coin, or digital tokens issued by the GOV); or (ii) a person located in Russia, Iran, North Korea, or Cuba, or any entity that is owned or controlled by or in a joint venture with such persons.

In the upcoming months, we will likely continue to see OFAC issue new GLs refining existing authorizations or gradually loosening sanctions with narrow authorizations allowing for further opportunities of US investment in Venezuela. In the event of new elections and a transition to democracy, we could see more drastic changes to OFAC’s Venezuela-related sanctions program.

Recent Changes to the Venezuela-Related Sanctions Program

General License 46B (Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products)

On March 13, 2026, OFAC issued Venezuela GL No.46B¹ authorizing certain transactions involving Venezuelan-origin oil or petrochemical products. Specifically, the GL authorizes “an established U.S. entity”² to engage in certain transactions — including those involving the GOV, PdVSA, or any entity in which PdVSA owns (directly or indirectly) a 50% or greater interest (PdVSA Entities) — that are ordinarily incident and necessary to the lifting (which refers to the physical loading and removal of oil from a terminal, storage facility, or production site for delivery to a buyer), export, reexport, sale, resale, supply, storage, marketing purchase, delivery, or transportation of Venezuelan-origin oil, including refining of such oil, or of Venezuelan-origin petrochemical products. For purposes of GL 46B, the term “petrochemical products” includes fertilizer products and fertilizer precursor chemicals, including the chemicals listed in the Annex of the general license.

OFAC issued twelve new Venezuela-related Frequently Asked Questions (FAQs): FAQs 1226-1235, 1237, and 1238, which clarify the scope of GL 46B and include additional definitions. Importantly, FAQ 1227 delineates the specific activities authorized and not authorized by GL 46B. For example, FAQ 1227 states that the following activities are authorized:

• engaging in commercial, legal, and technical discussions necessary to scope purchases of Venezuelan-origin oil, including with third-party legal, commercial, or due diligence consultants
• conducting safety, environmental, and other relevant inspections, including site surveys
• arranging logistics, security services, delivery points, and shipping preparation, including obtaining marine insurance and engaging with relevant port or maritime authorities of the GOV or their personnel
• conducting certain downstream activities³, including the refining and resale of Venezuelan-origin oil
• coordinating payment structures, including payments in the form of swaps of oil, diluents, or refined petroleum products, among others
• making required repairs and maintenance to pipeline, storage, or port infrastructure necessary to effectuate the loading of vessels; or the financing of related cargos or receivables

In contrast, the following activities, among other things, are not authorized under GL 46B:

• transactions involving 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 China
• the unblocking of any property blocked pursuant to the Venezuela Sanctions Regulations
• any transaction involving a blocked vessel

General License No. 47 (Authorizing the Sale of US-Origin Diluents to Venezuela)

On February 3, 2026, OFAC issued Venezuela GL No. 47, which authorizes certain transactions, including those involving the GOV, PdVSA, or PdVSA Entities, that are ordinarily incident and necessary to the export, reexport, sale, resale, supply, storage, marketing, delivery, or transportation of US-origin diluents to Venezuela. For the purposes of 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.⁴

Relatedly, on February 10, 2026, OFAC amended Venezuela GL No. 30B (Authorizing Certain Transactions Necessary to Port and Airport Operations) to remove a restriction regarding transactions or activities related to the export or reexport of diluents to Venezuela.

General License No. 48 (Authorizing the Supply of Certain Items and Services to Venezuela)

On February 10, 2026, OFAC issued Venezuela GL No. 48, which authorizes certain transactions, including those involving the GOV, PdVSA, or PdVSA Entities, that are ordinarily incident necessary to the supply of goods, technology, software, or services from the United States or by a US person for the exploration, development, or production of oil or gas in Venezuela. Note 1 to paragraph (a) of GL 48 further specifies that the authorized transactions include: (i) processing payments; (ii) arranging shipping and logistic services; (iii) obtaining marine insurance and protection and indemnity (P&I) coverage; (iv) and arranging port and terminal services, including with port authorities or terminal operators that are part of the GOV; and (v) maintenance⁵ of oil or gas operations in Venezuela, including the refurbishment or repair of items used for oil or gas exploration, development, or production activities.

In FAQ 1241, OFAC further clarified that examples of authorization transactions under GL 48 include:

• 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
• the processing of payments from the GOV or other authorized blocked persons for the underlying transactions. However, any monetary payment to the GOV or PdVSA or its majority-owned subsidiaries (other than payments for local taxes, permits, or fees) must be deposited into the Foreign Government Deposit Funds established pursuant to EO 14373, or another Treasury-instructed account.

General License No. 49A (Authorizing Negotiations of and Entry into Contingent Contracts for Certain Investments in Venezuela)

On March 13, 2026, OFAC issued Venezuela GL No. 49A,⁶ which authorizes, subject to certain exclusions, transactions including those involving the GOV, PdVSA, or PdVSA Entities, relating to the negotiation and entry into contingent contracts for new investment in oil, gas, petrochemical products, or electricity sector operations in Venezuela, provided that the performance of any such contract is made expressly contingent⁷ upon separate authorization from OFAC. Specifically, the GL authorizes prefatory steps for such activities, such as conducting commercial, legal, technical, safety, and environmental due diligence and assessments.

General License No. 50 (Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities)

On February 18, 2026, OFAC issued Venezuela GL No. 50A, which authorizes certain transactions, including those involving the GOV, PdVSA, or PdVSA Entities, relating to the oil or gas sector operations in Venezuela for entities listed in the Annex to GL 50A (i.e., BP PLC, Chevron Corp., Eni S.p.A., Etablissements Maurel & Prom SA, Repsol S.A., and Shell PLC).

According to FAQ 1242, transactions authorized by Venezuela GL 50A include:

• the lifting, export, reexport, 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
• the processing of payments related to any of the aforementioned activities

General License No. 51 (Authorizing Certain Activities Involving Venezuelan-Origin Gold)

On March 6, 2026, OFAC published Venezuela GL No. 51, which authorizes certain transactions, including those involving the GOV, PdVSA, or PdVSA Entities, that are ordinarily incident and necessary to the export, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin gold for importation into the United States, the refining of such gold in the United States, and the resale or exportation of such gold from the United States, by an established US entity. Similar to GL 46B, among other things, this GL does not authorize any transaction involving 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 China.

General License No. 52 (Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.)

On March 18, 2026, OFAC published Venezuela GL No. 52, which authorizes certain transactions involving PdVSA, including PdVSA Entities, by an “established U.S. entity.” Notably, the GL specifically does not authorize transactions prohibited by EO 13808 relating to bonds and certain other debt of the GOV or PdVSA.

On March 18, 2026, OFAC published FAQs 1245 and 1246, which clarify the scope of GL 52. In FAQ 1245, OFAC clarified that the specific activities authorized by GL 52 include:

• the lifting, export, reexport, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan oil or petroleum products of Venezuelan-origin oil and petroleum products
• the provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors
• entry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products sectors of Venezuela
• the formation of new joint ventures or other entities in Venezuela related to such activities
• all transactions ordinarily incident and necessary to such activities, including the performance of commercial, legal, technical, safety, and environmental due diligence and assessments related to the foregoing

FAQ 1246 explicitly states that GL 52 does not authorize the sale of certain shares of CITGO that are the subject of Crystallex International Corporation v. Bolivarian Republic of Venezuela. FAQ 1246 also cautions that a specific license is still required for the entry into a settlement agreement, or for the enforcement of any lien, judgement, or other order through judicial process that would affect property or interests otherwise blocked.

For More Information

Faegre Drinker’s International Trade & Customs team will continue to monitor additional regulatory and legislative developments in the days ahead.

Legal clerk Caitlin E. Kwalwasser contributed to this update.