On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two general licenses in the continuing relaxation of certain sanctions involving Venezuela.  These new general licenses authorize certain commercial and banking transactions in the country.

Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela.”  Authorizes transactions that are ordinarily incident and necessary to engaging in commercial-related negotiations of contingent contracts with the Government of Venezuela, provided that the entry into and performance of any such contract is made expressly contingent upon separate authorization from OFAC.  The general license provides definitions of the terms “Government of Venezuela” and “contingent contracts.”  It also sets forth other conditions that must be followed for such transactions.

Venezuela General License 57, “Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals.” Authorizes transactions that are ordinarily incident and necessary to the provision, exportation, or reexportation, directly or indirectly, of financial services to, from, or for the benefit of the following persons:  (1) Banco Central de Venezuela; (2) Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela); (3) Banco Digital de los Trabajadores Banco Universal C.A.; (4) Banco del Tesoro, C.A. Banco Universal (Banco del Tesoro); and (5) any entity in which one or more of the above entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interests. The general license provides a definition of the term “financial services,” and sets forth other conditions that must be followed for such transactions.

Under both licenses, there remain specific transactions and payment terms that are not authorized. Thus, the terms of each general license and continuing restrictions on certain transactions must be carefully reviewed.

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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.