- with Finance and Tax Executives
- with readers working within the Banking & Credit industries
On January 29, 2026, the U.S. Department of the Treasury Office of Foreign Assets Control ("OFAC") issued Venezuela General License 46 ("GL 46") authorizing certain commercial activities related to the sale, purchase, transport, and export of Venezuelan-origin oil that were previously prohibited under the Venezuela Sanctions Regulations. Notably, the transactions authorized by GL 46 may involve otherwise blocked entities including the Government of Venezuela, Petroleos de Venezuela, S.A. ("PdVSA"), or any entity in which PdVSA owns a 50% or greater interest.
Authorization Limits
At its core, GL 46 authorizes "established U.S. entities" to engage in transactions that are "ordinarily incident and necessary" to certain activities involving Venezuelan-origin oil, including refining of such oil. However, the GL specifies that transactions involving contracts with the Government of Venezuela, PdVSA, or PdVSA entities must be governed by U.S law and specify that any dispute resolution must occur within the U.S. In addition, payments made to blocked parties such as PdVSA or PdVSA entities must be made to the Foreign Government Deposit Funds, as defined in Executive Order 14373 of January 9, 2026, or other Treasury-directed accounts, limiting the ability of sanctioned actors to access or redirect funds outside Treasury oversight.
Crucially, GL 46 is not available to all parties. OFAC has confined its scope to "established U.S. entities" which is defined as entities organized under U.S. law on or before January 29, 2025. Newly formed entities or structures created to take advantage of the license cannot rely on GL 46. Additionally, the GL specifically does not authorize the following:
- Transactions with payment terms involving debt swaps, payments in gold, or digital currency, coin, or tokens issued by, for, or on behalf of the Government of Venezuela;
- Transactions involving persons located in or organized under the laws of Russia, Iran, North Korea, Cuba, or any entity that is owned or controlled by or in a joint venture with such persons;
- Transactions involving Venezuelan or U.S. entities that are owned or controlled by or in a joint venture with a Chinese party;
- The unblocking of property under the Venezuelan Sanctions Regulations;
- Transactions involving sanctioned vessels.
Reporting Obligations for Global Sales
Finally, GL 46 also introduces reporting requirements where Venezuelan-origin oil is exported or resold to destinations outside the United States. U.S. persons relying on the license for such third-country transactions must report those activities via email to both the U.S. Department of State and the U.S. Department of Energy. Such reports must contain information identifying the parties involved in the transactions, quantities, values, and countries of destination, transaction dates, and a report of taxes or fees paid to the Government of Venezuela. Reports are due ten days after the execution of the first transaction outside the U.S. and then every 90 days thereafter if the transactions are ongoing.
***
GL 46 presents very targeted sanctions relief, not a broad authorization. Companies considering Venezuela-related transactions should expect heightened regulatory scrutiny and should engage in careful planning and compliance judgment.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
