UPDATE: Additional Changes to the Venezuela Sanctions Program Impacting the Energy, Minerals, Financial Services, and Aviation Sectors

At a Glance

• Since our March 2026 Venezuela client alert, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued various new and amended, Venezuela-related general licenses (GLs) that target key sectors, such as energy, minerals, financial services, and aviation.
• Recent OFAC GLs are consistent with the US government's stated commitment of expanding US investment in the Venezuelan economy. Notably, there has not yet been any revocation of Venezuela-related legal authorities. As a result, OFAC could at any time revoke a general license, which would result in sanctions "snapping back" into place. We, therefore, recommend companies to explore potential contractual protections for any transaction undertaken pursuant to a general license. 
• Companies interested in pursuing investment and commercial opportunities in Venezuela pursuant to OFAC GLs will need to carefully consider the scope, requirements (including reporting requirements to the Departments of State, Energy, and Interior), and limitations of each license. Companies should also be cognizant of any additional licensing requirements, such as export licensing requirements from the US Department of Commerce's Bureau of Industry and Security.

Additional Changes to the Venezuela Sanctions Program

Since the publication of our March 2026 client alert discussing recent OFAC GLs concerning Venezuela, OFAC has issued various new and amended GLs and FAQs, the most significant of which are described below. 

The majority of the GLs do not authorize any transaction involving: (i) payment terms that are commercially unreasonable (e.g., debt swaps, payments in gold or denominated in digital currency, digital coin, or digital tokens issued by the Government of Venezuela (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.

Certain transactions under GLs 54 and 58 contain reporting requirements to the US Department of State, and/or the US Department of the Interior. Notably, OFAC issued FAQ 1248 clarifying that: (i) parties engaged in the primary authorized activity are responsible for complying with the applicable reporting requirements; and (ii) parties only indirectly involved or providing services ancillary to the primary authorized activity are not required to file reports pursuant to the applicable license.

Venezuela's Minerals Sector

General License No. 54A (Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela)

On June 10, 2026, OFAC issued Venezuela GL No. 54A, authorizing all transactions prohibited by the Venezuela Sanctions Regulations (VSR), including those involving the GOV and CVG Compañía General de Mineria de Venezuela CA (Minerven) that are ordinarily incident and necessary to the provision from the United States or by a US person of goods, technology, software, or services for the exploration, development, mining, extraction, processing, refining, or production of minerals, including gold, in Venezuela. Notably, this general license expands upon the authorized activities involving Venezuela-origin minerals in GL 51A. 

GL 54A includes the following conditions: (i) any contract for authorized transactions must 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 must occur in the United States, the United Kingdom, France, or Singapore; and (ii) any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, must be made into the Foreign Government Deposit Funds or any other account as instructed by the US Treasury Department.

General License No. 55 (Authorizing Negotiations of and Entry into Contingent Contracts for Certain Investment in Venezuela's Minerals Sector)

On March 27, 2026, OFAC issued Venezuela GL No. 55, which authorizes all transactions prohibited by the VSR that are ordinarily incident and necessary to negotiation and execution of contingent contracts that are related to new investment in the minerals sector of Venezuela, including the gold sector, provided that the performance of any such contract is made expressly contingent upon separate authorization from the OFAC. Transactions authorized by the general license include: (i) "negotiating and entering into contingent contracts to engage in new exploration, development, mining, extractions, processing, refining, or production activities in Venezuela's minerals sector, to expand existing operations in Venezuela and to form new joint ventures or other entities in Venezuela related to the foregoing activities" and (ii) "prefatory steps for the aforementioned activities, such as conducting commercial, legal, technical, safety, and environmental due diligence and assessments." These transactions may involve the GOV; Minerven; or any entity in which Minerven owns, directly or indirectly, a 50% or greater interest.

Venezuela's Financial Services Sector 

General License No. 57 (Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals)

On April 14, 2026, OFAC issued Venezuela GL No. 57, which authorizes all transactions prohibited by the VSR that are ordinarily incident and necessary to the provision, export, or reexport, directly or indirectly, of financial services to, from, or for the benefit of the following Venezuela banks:

1. Banco Central de Venezuela
2. Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela)
3. Banco Digital de los Trabajadores Banco Universal C.A.
4. Banco del Tesoro, C.A. Banco Universal (Banco del Tesoro)
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.

The GL also authorizes such transactions with any individual whose property and property interests are blocked solely pursuant to Executive Order 13884 because of their status as a GOV employee, excluding any individual identified on OFAC's Specially Designated Nationals and Blocked Persons List. 

The GL broadly defines the term "financial services" to include a large swath of activity, such as:

maintaining, operating, or closing of accounts; loans; transfers; transfers of funds; banking services; money transfer services; collection; presentment; promise; order; consignment; the acceptance of deposits; insurance; guarantees; cash withdrawals; check services; Automated Clearing House (ACH) transfers; wire transfers; debit card, prepaid card, Automated Teller Machine transactions, and any other payments as defined under the Uniform Commercial Code Article 3-602; the issuance and use of payment cards and digital wallets; currency exchange; U.S. dollar-denominated banking, payment, and correspondent account services; services in connection with the collection, forwarding, processing, or receipt of funds or remittances; services in connection with the processing or receipt of salary, pension, annuity, payroll, and other employment-related payments or benefits; transfers of funds sent through mobile money, mobile wallets, digital bank accounts, credit cards, debit cards, online payments, or other digital technology; related safety, fraud-prevention, screening, authentication, cybersecurity, and security services and technologies; investments; securities; and commodity futures or options.

US banks processing transactions authorized under the banks may rely on the originator or beneficiary of a funds transfer with regard to compliance with this general license, provided that the processing bank does not know or have reason to know that the transaction is not in compliance with this general license.

General License No. 58 (Authorizing Certain Services to the Government of Venezuela in Connection with Potential Debt Restructuring)

On May 5, 2026, OFAC issued Venezuela GL No. 58, which authorizes the provision of legal, financial advisory, and consulting services to the GOV connected to potential debt restructuring.

Any person that provides legal, financial advisory, and consulting services pursuant to this general license needs to provide a copy of the signed contract for such services to the Department of State and the Department of Energy within 10 business days of execution. 

The GL does not authorize, among other activities: (i) "the restructuring, transfer, or settlement of debt of the GOV, including debt of Petróleos de Venezuela, S.A. (PdVSA), or direct negotiations between the GOV, including PdVSA, and creditors regarding such restructuring, transfer, or settlement;" or (ii) "the entry into a settlement agreement or the enforcement of any lien, judgment, arbitral award, decree, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property blocked pursuant to the VSR."

Venezuela's Aviation Sector 

General License No. 59 (Authorizing the Supply of Certain Items and Services Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A. (Conviasa) 

On June 18, 2026, OFAC issued Venezuela GL No. 59, which authorizes all transactions prohibited by Executive Order 13884 involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A. ("Conviasa") or any entity in which Conviasa owns, directly or indirectly, a 50% or greater interest (collectively, "Conviasa Entities"), or any aircraft in which such entities have an interest, that are ordinarily incident and necessary to the provision from the United States or by a US person of goods, technology, software, or services for the maintenance, repair, upgrade, refurbishment, improvement, safety, or airworthiness of such aircraft. 

The transactions authorized by this GL include "the processing of payments, arranging shipping, logistics, customs clearance, and delivery services; the sale, supply, installation, inspection, testing, maintenance, repair, replacement, refurbishment, upgrade, or improvement of aircraft parts, components, equipment, software, and technology; software updates; technical support; and other services related to the maintenance, repair, upgrade, refurbishment, improvement, safety, or airworthiness of aircraft in which Conviasa or a Conviasa Entity has an interest."

Parties operating under this general license are still required to comply with export licensing requirements administered and enforced by BIS.

Other Transactions Involving the GOV

General License No. 53 (Official Missions of the Government of Venezuela to the United States)

On March 24, 2026, OFAC issued Venezuela GL No. 53, which authorizes transactions prohibited by the VSR that are related to the provision and payment of goods or services in the United States to official missions of the GOV to the United States or to permanent missions of the GOV to international organizations in the United States, provided that: (i) the goods or services are for the conduct of the official business of the missions, for personal use of the employees of the mission in the United States, or for persons who share a common dwelling as a family member or dependent of such an employee; (ii) the transaction does not involve the purchase, sale, financing, or refinancing of real property; and (iii) the transaction is not otherwise prohibited by law.

General License No. 56 (Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela)

On April 14, 2026, OFAC issued Venezuela GL No. 56, which authorizes all transactions prohibited by Executive Order 13884 ordinarily incident and necessary to engaging in commercial-related negotiations of contingent contracts with the GOV, provided that the entry into and performance of any such contract is made expressly contingent upon separate authorization from the OFAC. For purposes of the GL, the term "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."

General License No. 60 (Authorizing Transactions Related to Earthquake Relief Efforts in Venezuela)

On June 25, 2026, OFAC issued Venezuela GL No. 60, which authorizes "all transactions related to earthquake relief efforts in Venezuela" through October 23, 2026. Note 1 to paragraph (a) of the general license clarifies that the license covers processing and transferring of funds on behalf of third-country persons to or from Venezuela in support of relief efforts. Additionally, US financial institutions and money transmitters are permitted to "rely on the originator of a funds transfer with regard to compliance" with the license requirements so long as there is no knowledge or reason to know that the funds transfer is noncompliant. The GL does not authorize the unblocking of any property blocked pursuant to the VSR. 

On July 17, 2026, OFAC published FAQ 1263, which clarifies that payments made pursuant to GL 60, including payment of taxes, tolls, and fees to the GOV, do not need to be made into the Foreign Government Deposit Funds Account at the Department of the Treasury.

Updates Clarifying Governing Law Requirements and Expanding Available Jurisdictions for International Dispute Resolution 

On June 10, 2026, OFAC issued updated Venezuela GL No. 46C, Venezuela GL No. 47A, Venezuela GL No. 48B, Venezuela GL No. 50B, Venezuela GL No. 51B, Venezuela GL No. 52A, and Venezuela GL No. 54A. Each of these updated licenses included language clarifying that transactions with the GOV, PdVSA, or PdVSA Entities will require: "(i) the terms of the contract be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States and (ii) dispute resolution proceedings relating to the contract occur in the United States, the United Kingdom, France, or Singapore." Additionally, each general license includes a note clarifying that contractual terms that recognize "certain aspects of the underlying activity in Venezuela may be subject to applicable Venezuelan law and regulations, including laws and regulations governing the exercise of Venezuela's sovereign regulatory authority, administrative permits and licenses, concessions, labor, environmental, health and safety, and other mandatory regulatory requirements" are permissible. 

For More Information

Faegre Drinker's customs and international trade team will continue to monitor additional regulatory and legislative developments in the days ahead.

Summer associate Coley Martin contributed to this update.