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Overview
On February 3, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued Venezuela-related General License 47 ("GL 47"), "Authorizing the Sale of U.S.-Origin Diluents to Venezuela." The license authorizes a defined set of activities related to the exportation and supply of U.S.-origin diluents to Venezuela that would otherwise be prohibited under the Venezuela Sanctions Regulations ("VSR"), 31 CFR part 591. We previously posted about GL 46 and GL 5U on February 3, 2025.
Scope of GL 47
GL 47 permits U.S. persons to engage in transactions that are ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, marketing, delivery, or transportation of U.S.-origin diluents to Venezuela. This authorization applies even when the transactions involve the Government of Venezuela, Petróleos de Venezuela, S.A. ("PdVSA"), or any entity in which PdVSA owns a 50 percent or greater interest ("PdVSA Entities"). However, the license requires that any contract with the Government of Venezuela, PdVSA, or PdVSA Entities specify that U.S. law governs the agreement and that any related dispute resolution must occur in the United States.
The license also clarifies the types of supporting activities that fall within the authorization. GL 47 states that the permitted transactions include the processing of payments, arranging shipping and logistics services (including vessel chartering), obtaining marine insurance and protection and indemnity coverage, and arranging port and terminal services, including services provided by Venezuelan port authorities or terminal operators that are part of the Government of Venezuela. These supporting services are explicitly included in Note 1 to paragraph (a) of the license.
Key Limitations
GL 47 contains several significant limitations. Similar to GL 46, the license does not authorize payment terms that are not commercially reasonable, nor does it permit debt swaps, payments in gold, or payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro. It also prohibits any transaction involving persons located in or organized under the laws of Iran, North Korea, or Cuba, as well as any entity owned or controlled by, or in a joint venture with, such persons. Unlike GL 46, GL 47 does not include Russia among the prohibited counterparties. In addition, GL 47 does not authorize the unblocking of property blocked pursuant to the VSR, except as expressly allowed under paragraph (a), and it does not permit any transaction involving a blocked vessel.
The note to GL 47 emphasizes that the license does not relieve any person of compliance obligations administered by other federal agencies, including the Department of Commerce's Bureau of Industry and Security. This clarification reinforces that parties relying on GL 47 must continue to assess potential export control requirements independent of OFAC's authorization.
Key Takeaways
GL 47 establishes a targeted authorization framework permitting defined transactions involving the exportation, reexportation, sale, resale, supply, storage, marketing, delivery, or transportation of U.S.-origin diluents to Venezuela, including when such transactions involve the Government of Venezuela, PdVSA, or PdVSA‑owned entities. The license provides a clearer pathway for U.S. persons to engage in compliant diluent‑related activities while maintaining strict guardrails on contract terms, counterparties, payment structures, and the use of digital currency. We are happy to discuss the applicability of GL 47 to specific operations in further detail.
We emphasize that the situation remains dynamic, following the recent issuance of multiple licenses surrounding Venezuela as highlighted above. We will continue to post updates as additional licensing emerges and update this post in the event of further amendments.
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.
