ARTICLE
10 July 2026

OFAC Continues Its Incremental Approach To Venezuela: New Licenses Facilitate Communications, Aviation, And Relief Activities

LB
Lewis Brisbois Bisgaard & Smith LLP

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Founded in 1979 by seven lawyers from a premier Los Angeles firm, Lewis Brisbois has grown to include nearly 1,400 attorneys in 50 offices in 27 states, and dedicates itself to more than 40 legal practice areas for clients of all sizes in every major industry.
The U.S. Treasury's Office of Foreign Assets Control has issued a series of new general licenses that incrementally adjust Venezuela sanctions, creating targeted pathways for telecommunications services, aircraft safety operations, and earthquake relief activities. These authorizations maintain the broader sanctions framework while addressing specific operational and humanitarian needs, including a further delay in enforcement rights related to the PdVSA 2020 bond and its CITGO collateral.
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Continued Refinement in Venezuela Sanctions

Since our last alert, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has continued to refine the Venezuela sanctions program through a series of targeted authorizations and related guidance that ease certain restrictions. Recent actions address telecommunications and delivery services, aircraft maintenance and safety, earthquake relief efforts, and the timing of enforcement rights associated with the PdVSA 2020 bond, while leaving the broader sanctions framework largely unchanged.

GL 24A: Continuing Authorizations for Telecommunications and Delivery Services

On June 18, 2026, OFAC issued General License 24A (“GL 24A”), authorizing transactions involving the Government of Venezuela that are incident to the receipt and transmission of telecommunications, including the provision of communications services that necessarily involve Government of Venezuela entities blocked solely pursuant to Executive Order 13884. The license also allows common carriers to transmit mail and packages to, from, and within Venezuela where such activities involve the Government of Venezuela. GL 24A replaces and supersedes prior GL 24, while continuing to prohibit dealings with other blocked persons and preserving all other applicable sanctions restrictions.

GL 5X: Continued Delay of PdVSA 2020 Bond Enforcement

On June 18, 2026, OFAC issued General License 5X (“GL 5X”), replacing and superseding GL 5W. For additional background regarding GL 5W, see our previous alert. At first glance, GL 5X appears nearly identical to its predecessor. In substance, it is. The sole operative change is OFAC’s decision to postpone the authorization date for transactions involving the PdVSA 2020 8.5% bond from June 19, 2026, to August 4, 2026. As OFAC explained in updated FAQ 595, the GL 5 series addresses restrictions under Executive Order 13835 that affect bondholders’ ability to exercise rights against the CITGO shares pledged as collateral for the bond. Between October 24, 2019 and August 4, 2026, there remains no effective authorization permitting transactions related to the sale or transfer of those CITGO shares in connection with the PdVSA 2020 bond, absent a specific license.

By extending the effective date yet again, OFAC continues to control the timing of potential enforcement activity involving the PdVSA 2020 bond and its associated CITGO collateral, while signaling that it would view favorably specific license applications supporting a restructuring or refinancing of the bond.

GL 59: Authorizing Aircraft Safety, Maintenance, and Repair Activities

On June 18, 2026, OFAC issued General License 59 (“GL 59”), permitting U.S. persons to provide goods, technology, software, and services to Conviasa, Venezuela’s state-owned airline, and certain affiliated entities for purposes related to aircraft maintenance, repair, refurbishment, upgrades, safety, and airworthiness. The authorization extends to a broad range of supporting activities, including the sale and installation of aircraft parts and equipment, software updates, technical support, payment processing, shipping, logistics, customs clearance, and delivery services. OFAC also authorizes transactions involving the Government of Venezuela that are ordinarily incident and necessary to these activities

The license, however, contains significant limitations. GL 59 prohibits non-commercial payment arrangements, including debt swaps, payments in gold, and payments denominated in digital currency, digital coins, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro. The license also prohibits transactions involving persons from Russia, Iran, North Korea, and Cuba, certain China-related ownership structures, military or intelligence activities, and dealings with blocked persons outside the scope of the authorization.

While OFAC continues to restrict dealings with Conviasa generally, the license creates a pathway for U.S. companies to provide products and services necessary to maintain the safety and operational airworthiness of aircraft in which Conviasa has an interest.

GL 60: Authorizing Earthquake Relief Efforts

On June 25, 2026, OFAC issued General License 60 (“GL 60”), allowing transactions otherwise prohibited by the Venezuela Sanctions Regulations that are related to earthquake relief efforts in Venezuela through October 23, 2026. Significantly, the license authorizes the processing and transfer of funds in support of relief activities, including transactions involving third-country persons sending funds to or from Venezuela for earthquake-related assistance. GL 60 also permits U.S. financial institutions and registered money transmitters to process qualifying payments and, in certain circumstances, rely on information provided by the originator of a funds transfer when determining whether the transaction falls within the scope of the authorization. The license does not authorize the unblocking of blocked property or activities prohibited under other sanctions authorities. By expressly facilitating the movement of relief-related funds, OFAC has reduced a key practical obstacle to providing assistance while leaving broader Venezuela sanctions restrictions in place.

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.

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