On January 29, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil.” The general license authorizes all transactions prohibited by the Venezuela Sanctions Regulations, 31 C.F.R part 591, including those involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, “that are ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, including the refining of such oil, by an established U.S. entity.”
The scope of this general license authorization is limited to an established U.S. entity, defined as “any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.” OFAC notes that the transactions authorized “include arranging shipping and logistics services, including chartering vessels, obtaining marine insurance and protection and indemnity (P&I) coverage, and arranging port and terminal services, including with port authorities or terminal operators that are part of the Government of Venezuela.” The general license also authorizes “commercially reasonable payments in the form of swaps of crude oil, diluents, or refined petroleum products.”
Further, the general licenses is applicable provided that: (1) Any contract for such transactions “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 occur in the United States;” and (2) “Any monetary payment to a blocked person is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury.”
Any person that exports, reexports, sells, resells, or supplies Venezuelan-origin oil to countries other than the United States pursuant to this general license must provide a detailed report to the Departments of State and Energy ten days after the execution of the first of such transactions, and every 90 days thereafter while such transactions are ongoing.
While this general license is intended to encourage U.S. oil companies to return to Venezuela and reinvest in that country’s oil infrastructure and production, there remain specific transactions and payment terms that are not authorized. Thus, the terms of the general license and continuing restrictions on certain transactions must be carefully reviewed.