The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued several Venezuela-related general licenses, authorizing activities that would otherwise be prohibited under the Venezuela Sanctions Regulations under 31 CFR part 591 (VSR) and that are essential to supporting the production of heavy Venezuelan crude oil. General License No. 46A, issued on Feb. 10, 2026, authorizes certain activities involving Venezuelan-origin oil; General License No. 47, issued on Feb. 3, 2026, authorizes the sale of U.S.-origin diluents to Venezuela; General License No. 48, issued Feb. 10, 2026, authorizes the supply of certain items and services to Venezuela; and General License No. 30B, issued on Feb. 10, 2026, authorizes certain transactions necessary to port and airport operations.
While Venezuela remains subject to a complex U.S. sanctions and export controls framework, these general licenses (GLs) ease some of the sanctions the United States has imposed on Venezuela’s oil sector. However, the authorizations do not by themselves permit production of Venezuelan-origin oil, oil exploration activities, or financing for the purchase of Venezuelan-origin oil, and are subject to specific conditions, exclusions, and reporting requirements.
Overview of Current Sanctions on the Venezuela Oil Sector
The VSR implement U.S. sanctions relating to Venezuela, including a series of executive orders and statutory authorities that prohibit or restrict certain transactions and dealings with Venezuela or specified Venezuelan persons and interests.
Additional executive orders grant authority to the treasury secretary, in consultation with the secretary of state, to impose sanctions on individuals and entities that engage in transactions involving Venezuela’s oil and gas sector. Executive Order 13808, published Aug. 24, 2017 — as amended by Executive Order 13857 — published Jan. 25, 2019, focuses on financial transactions by prohibiting U.S. persons from dealing in new debt or purchasing securities of any kind, including debt and equity securities from the government of Venezuela and state-owned entities like Petróleos de Venezuela, S.A. (PDVSA), the main state-owned oil and gas company of Venezuela.
Executive Order 13850, published Nov. 1, 2018, authorizes blocking sanctions on persons operating in the oil, gas, or gold sectors of the Venezuelan economy. OFAC has designated PDVSA, the main state-owned oil and gas company of Venezuela1, and other companies for operating in Venezuela’s oil sector. In addition, the U.S. government has blocked several oil tankers upon identifying association with blocked persons. Executive Order 13884, published Aug. 5, 2019, imposed blocking sanctions on the Venezuelan government. This executive order prohibits most dealings between U.S. persons and Venezuelan state-owned entities and provides that all property and interests in property of the government of Venezuela are blocked, including state entities that control oil/gas revenue and financial institutions.
Sanctions Implications
Unless authorized by an OFAC-issued general or specific license, all property and interests in property of parties designated under the above-referenced executive orders that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any local or foreign entities that are at least 50% owned — directly, or indirectly — by one or more blocked persons are also blocked.
Secondary sanctions allow OFAC to sanction non-U.S. persons for engaging in activities deemed contrary to U.S. sanctions policy, even when those persons have no ties to the United States. For example, non-U.S. persons can be sanctioned for providing “material assistance” to persons sanctioned under the Venezuela sanctions program, including PDVSA.
Authorized Transactions
General License No. 46A
As of Feb. 10, 2026, General License No. 46A (GL 46A) authorizes certain transactions otherwise prohibited under the VSR, including transactions involving the government of Venezuela, PDVSA, or any entity owned or controlled by PDVSA, provided those transactions are (1) “ordinarily incident and necessary” to the lifting, exportation, re-exportation, sale, resale, supply, storage, marketing, purchase, delivery, transportation, or refining of Venezuelan origin oil; and (2) conducted by an “established U.S. entity.” The term “lifting” in this context means the physical loading and removal of oil from a terminal, storage facility, or production site for delivery to a buyer. We note that for purposes of the GL, the definition of “Venezuelan origin oil” also encompasses petroleum products that are obtained from the processing of crude oil (including lease condensate), natural gas, and other hydrocarbon compounds. This includes unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas, and miscellaneous products. It does not, however, include natural gas, biofuels, methanol, or other non-petroleum fuels.
Authorized transactions include: (1) shipping and logistics services, such as chartering vessels, and obtaining marine insurance and protection and indemnity coverage; and (2) port and terminal services, including services provided by port authorities or terminal operators that are part of the government of Venezuela.
GL 46A does not authorize the production of oil or other exploration or production activities, nor does it authorize activities related to investment in the Venezuelan oil sector. While GL 46A does not broadly authorize the financing for the purchase of Venezuelan oil, OFAC has clarified2 that financing-related cargoes or receivables falls within the scope of authorized activities. GL 46A also authorizes “commercially reasonable” payments in the form of swaps of crude oil, diluents, or refined petroleum products; however, payment terms involving debt swaps are not authorized. OFAC has clarified that “commercially reasonable” means “terms that are consistent with prevailing market and industry standards for like or similar products produced by a company of similar size and scope, while taking into account characteristics such as quality, quantity, pricing, performance, and safety, among others. Commercially reasonable terms include terms related to, among other things, the governance, economics, operations, and legal/compliance requirements of a contract negotiated at arm’s length between two or more parties.”
There are various ambiguities in GL 46A that remain. In addition, it remains unclear whether certain ancillary transactions are authorized (including hedging transactions or various financing structures).
General License No. 47
From Feb. 3, 2026, OFAC’s General License No. 47 (GL 47) authorizes transactions that are “ordinarily incident and necessary” to the exportation, re-exportation, sale, resale, supply, storage, marketing, delivery, or transportation of U.S.-origin diluents (an undefined term) to Venezuela. The authorized transactions generally align with those in GL 46A (e.g., shipping, logistics, port, and terminal services), but GL 47 also expressly authorizes the processing of payments by the government of Venezuela for the sale of U.S.-origin diluents to Venezuela. Because GL 47 is structured to authorize the supply of diluents rather than participation in Venezuelan oil production or ownership of Venezuelan hydrocarbon products, activities related to the lifting and purchase of oil products remain unauthorized.
Unlike GL 46A, GL 47 does not require the involvement of an “established U.S. entity.” Parties may make payments for diluents through normal banking channels, unlike purchases of Venezuelan oil.
Neither GL 46A nor GL 47 have a specified expiration date, although they can be revoked at any time.
General License No. 48
As of Feb. 10, 2026, General License No. 48 (GL 48) authorizes transactions “ordinarily incident and necessary” to the provision from the Unites States or by a U.S. person of goods, technology, software, or services for the exploration, development, or production of oil or gas in Venezuela.
The conditions for performing activities under GL 48 are mostly the same as the ones provided by GL 46A, but GL 48 expressly does not authorize (1) the formation of new joint ventures or other entities in Venezuela to explore or produce oil or gas; or (2) transactions or dealings related to the exportation or re-exportation of diluents, directly or indirectly, to Venezuela. However, GL 48 authorizes transactions related to the maintenance of oil or gas operations in Venezuela, including the refurbishment or repair of items used for oil or gas exploration, development, or production activities.
General License No. 30B
Through General License No. 30B (GL 30B) issued on Feb. 10, 2026, OFAC authorizes transactions “ordinarily incident and necessary” to operations or use of ports and airports in Venezuela. However, GL 30B does not authorize transactions with (1) any blocked person other than the National Institute of Aquatic Spaces (INEA) or any entity in which INEA owns, directly or indirectly, a 50% or greater interest, or (2) any government of Venezuela person that is blocked solely pursuant to Executive Order 13884, unless separately authorized.
Additional Conditions for Parties Using the GLs
GL 46A, GL 47, GL 48, and GL 30B contain a number of conditions and restrictions that must be satisfied for a transaction to be authorized. For example, under GL 46A, GL 47, and GL 48, any contract entered into with the government of Venezuela, PDVSA, or any entity in which PDVSA owns, directly or indirectly, a 50% or greater interest must be governed by U.S. law and provide that any dispute resolution (covering both litigation and arbitration) will occur in the United States. OFAC has clarified that this dispute resolution requirement does not apply to indirect parties or indirect counterparties participating in transactions authorized by GL 46A, such as the provision of shipping or insurance services.
Additionally, under GL 46A, only those transactions conducted by an “established U.S. entity” are authorized. An “established U.S. entity” is defined as any entity organized under the laws of the United States or any jurisdiction within the United States on or before Jan. 29, 2025. However, OFAC has clarified in subsequent guidance that non-U.S. persons may engage in transactions or provide services that are ordinarily incident and necessary to the established U.S. entity’s transactions authorized by GL 46A.
GL 46A and GL 48 provide that payments to a blocked person for authorized transactions, except for payments for local taxes, permits, or fees, must be made into the Foreign Government Deposit Funds3 or any other account as instructed by the U.S. Department of the Treasury. OFAC has not provided guidance, however, on how to make such authorized payments into these accounts. Transactions may not involve payment terms that are not commercially reasonable, payments denominated in digital currencies issued on behalf of the government of Venezuela (including the petro, the country’s state-backed digital token). These GLs also prohibit debt swaps and payments in gold.
The GLs also place limits on involvement by persons in countries subject to U.S. sanctions or export controls, though the exact limits vary by GL. For example, nder GL 46A and GL 48, activities involving persons or entities organized under the laws of — or located in — Russia, Iran, North Korea, or Cuba, including entities owned or controlled by the same, directly or indirectly, or entities participating in joint ventures with such persons, are not authorized. GL 48 applies the same restrictions to any person or entity organized or located in China, while GL 46A restricts only certain types of dealings with entities in China.
Reporting Obligations
The GLs impose reporting obligations on any person that exports, re-exports, sells, resells, or supplies (1) Venezuelan-origin oil to countries other than the United States in reliance on GL 46A; (2) U.S.-origin diluents to Venezuela pursuant to GL 47; or (3) goods, technology, software, or services pursuant to GL 48. Such persons must submit detailed reports to the U.S. Department of State and the U.S. Department of Energy within 10 calendar days after the execution of the first authorized transaction and every 90 days thereafter while such transactions are ongoing. Each report must identify, for each transaction: (1) the parties involved; (2) the quantities and values; (3) the dates on which the transactions occurred; and (4) any taxes, fees, or other payments provided to the government of Venezuela (for transactions done under GL 46A and GL 48). Reports on transactions under GL 46A must also include the countries of ultimate destination.
Conclusion
The GLs authorize certain transactions involving Venezuelan-origin oil, sale of U.S.-origin diluents to Venezuela, supply of items and services to Venezuela, and port and airport operations in Venezuela that would otherwise be prohibited under the VSR. However, these authorizations are subject to specific conditions, exclusions, and reporting requirements, so careful analysis of all contours of potentially applicable GLs is important. Compliance program elements including contractual protections and payment and financial restrictions may help mitigate the risks of even inadvertent dealings with excluded or blocked parties. Further, the sanctions landscape with respect to Venezuela may continue to change, new sanctions or restrictions may be added at any time, and GLs may be revoked at any time, making ongoing vigilance essential.
* Special thanks to International Law Clerk Janelle Christie ˘ for contributing to this GT Alert.
˘ Not admitted to the practice of law.
1 On Jan. 28, 2019, OFAC designated Petroleos de Venezuela, S.A. pursuant to Executive Order 13850 for operating in the oil sector of the Venezuelan economy. OFAC also designated shipping companies operating in the oil sector on Dec. 11, 2025, and on Dec. 31, 2025.
2 OFAC’s published Venezuela-related Frequently Asked Questions 1227 and 1230 includes the financing of related cargoes or receivables within the list of authorized transactions under GL 46A.
3 Under Executive Order 14373, published Jan. 9, 2026, “Foreign Government Deposit Funds” means funds paid to or held by the United States government in designated U.S. Department of the Treasury accounts or funds on behalf of the government of Venezuela or its agencies or instrumentalities, including the Central Bank of Venezuela and PDVSA, that are derived from either the sale of natural resources from, or the sale of diluents to, the government of Venezuela or its agencies or instrumentalities.