OFAC Reaffirms Recent Licenses Along With New License in Response to Venezuela Earthquakes

In June, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a fresh round of new and amended Venezuela-related general licenses (GLs) targeting sectors such as energy, financial services, and aviation. Taken together, these actions signal OFAC’s continued recalibration of the Venezuela sanctions program — tightening restrictions in some areas while carving out narrow pathways for certain commercial and humanitarian activities. Companies with exposure to Venezuela should review these developments carefully to determine whether their operations fall within the scope of the new authorizations or, equally important, within the transactions that remain squarely prohibited.

These GLs continue the shift that began in January 2026 — after years of increasingly restrictive sanctions targeting Venezuela’s government and state-owned enterprises, OFAC has now issued more than a dozen general licenses authorizing significant new categories of oil, gas, mining, and financial-services activity involving Venezuela. These changes have opened new opportunities for business in Venezuela, subject to defined limits and OFAC’s ability to amend and withdraw. Indeed, the distinctions and carveouts present in OFAC’s General Licenses serves as an important reminder of the broader licensing requirements in place when conducting business with Venezuela while the U.S. continues to promote investment in this nation recently subject to comprehensive sanctions.

Permissible Activity Under Key General Licenses

Until early 2026, OFAC’s Venezuela program provided sanctions relief mainly through individual, company-specific licenses.[1] However, after Venezuela’s January 2026 hydrocarbons law reform, OFAC quickly began issuing categorical general licenses, rather than authorizing relief to one company at a time. In June, a flurry of activity resulted in the following General Licenses and/or their amendments:

General License 46[2] and its current amendments allow “established U.S. entities” (companies organized in the United States on or before January 29, 2025) to purchase, export, and refine Venezuelan-origin crude oil and petroleum products.
General License 47[3] permits the export of U.S.-origin diluents, which are needed to process Venezuela’s heavy crude, to Venezuela.
General License 48[4], as currently amended, authorizes U.S. persons to supply goods, technology, and services needed for oil, gas, and petrochemical exploration, development, and production, as well as electricity generation in Venezuela (though it does not authorize forming new joint ventures in Venezuela).
General License 49[5], as currently amended, allows companies to negotiate and sign contingent investment contracts covering Venezuela’s oil, gas, petrochemical, and electricity sectors, though each contract still requires separate OFAC approval before it can take effect. This license does not authorize performance.
General License 50B[6], as currently amended, goes further, authorizing actual oil and gas operations in Venezuela by six named companies, including Eni, Repsol, and Shell. Companies not on this list cannot rely on GL 50 to conduct operations.
General License 5X authorizes, effective August 4, 2026, all transactions related to the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 Percent Bond that would otherwise be prohibited under Executive Order 13835. Note that the authorization does not take effect until August 4, so transactions before that date in the bond remain prohibited, and market participants should plan accordingly.

While these General Licenses do not have fixed expiration dates, several of them have already undergone multiple amendments, reflecting how quickly OFAC is willing to adjust the program’s scope. On top of the potential for sudden amendment or recission, each license comes with conditions that will affect how a transaction is structured. For example, contracts with the Venezuelan government or PdVSA generally must be governed by U.S. law and resolved in U.S. courts; payments to blocked parties generally must be routed through U.S.-controlled accounts; payments in cryptocurrency are prohibited; and transactions involving parties connected to Russia, Iran, North Korea, Cuba, or China are excluded. Companies should confirm that each of these conditions is satisfied before assuming a general license covers a proposed transaction.

Availability of Specific Licenses

Beyond the general licenses, OFAC has also shown more willingness to grant specific licenses for transactions that fall outside the general licenses but align with current policy objectives. For example, OFAC has indicated a favorable view toward licenses the resale of Venezuelan-origin oil for use in Cuba, despite the limitation against Cuban transactions under the general licenses.[7] Companies pursuing a transaction that is not squarely covered by a general license should consider whether a specific license application is a viable path forward.

Cautious Compliance Optimism

Internally, multinational compliance departments can move from blanket prohibitions on Venezuela-related activities, toward transactions-specific review. The operative compliance question is no longer: Does this transaction involve Venezuela? Rather, companies should now ask: does this Venezuelan-related transaction fall within the scope of an applicable general or specific license?

However, the same licensing mechanism that allows OFAC to expand commercial opportunities also allows OFAC to restrict or remove them. Unlike statutory sanctions relief, none of which is currently pending before Congress, the licensing framework rests entirely on OFAC’s discretionary licensing authority. General licenses can be amended, narrowed, suspended, or revoked with little or no notice, and businesses should not treat the current framework as a permanent normalization of U.S.-Venezuela economic relations.

OFAC has already exercised this power twice in recent history. OFAC has previously authorized specific companies’ Venezuela operations through individual licenses, only to reverse course and convert those authorizations into wind-down periods when political conditions changed. More recently, in June 2026, OFAC issued a general license authorizing the sale of Iranian oil, only to revoke it entirely just over two weeks later following renewed conflict with Iran.[8] Businesses should assume that the current Venezuela licenses could be reversed on a similarly short timeline if political or security conditions change, but this month’s reaffirmation of the validity of these licenses indicates they may remain durable.

Takeaways for Your Business

For prospective transactions involving Venezuelan parties,

Assess whether a transaction fits within the scope of an applicable general license, including its conditions on counterparties, payment structures, and reporting obligations;
Screen all counterparties against OFAC’s sanctions lists;
Evaluate whether a specific license is needed, or would be advisable, for any activity not squarely covered by a general license; and
Build flexibility into contracts and compliance programs through sanctions clauses, termination rights, and contingency planning, in case the underlying license is amended or revoked.

Foley’s team of experienced trade and national security attorneys advises U.S. and multinational companies on sanctions compliance, export controls, and other regulatory issues affecting cross border operations, including in the energy sector. To discuss how Foley & Lardner LLP can assist with navigating Venezuela’s General and Specific Licenses, contact Olivia Singelmann ([email protected]), Jack Korba ([email protected]), Parker White ([email protected]), or Ahmad Murrar ([email protected]).

This article was prepared with the assistance of 2026 summer associate JJ Gramlich.

[1] See, e.g.,U.S. Department of the Treasury, Treasury Issues Venezuela General License 41 Upon Resumption of Mexico City Talks, Press Release (Nov. 26, 2022).

[2] Office of Foreign Assets Control, U.S. Department of the Treasury, General License No. 46A: Authorizing Certain Activities Involving Venezuelan-Origin Oil, 31 C.F.R. part 591 (June 2026) (amending General License No. 46 (Jan. 29, 2026)).

[3] Office of Foreign Assets Control, U.S. Department of the Treasury, General License No. 47A: Authorizing the Sale of U.S.-Origin Diluents to Venezuela, 31 C.F.R. part 591 (June 2026) (amending General License No. 47 (Feb. 3, 2026)).

[4] Office of Foreign Assets Control, U.S. Department of the Treasury, General License No. 48A: Authorizing the Supply of Certain Items and Services to Venezuela, 31 C.F.R. part 591 (June 2026) (amending General License No. 48 (Feb. 10, 2026)).

[5] Office of Foreign Assets Control, U.S. Department of the Treasury, General License No. 49A: Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela, 31 C.F.R. part 591 (June 2026) (amending General License No. 49 (Feb. 13, 2026)).

[6] Office of Foreign Assets Control, U.S. Department of the Treasury, General License No. 50B: Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities, 31 C.F.R. part 591 (June 2026) (amending General License No. 50 (Feb. 13, 2026)).

[7] Office of Foreign Assets Control, U.S. Department of the Treasury, FAQ 1238: Would OFAC approve the resale of Venezuelan origin oil to Cuba?

[8] John F. Korba, Olivia S. Singelmann & Teresa N. Taylor, OFAC Rescinds Iranian Sanctions Relaxation Following Renewed Conflict, Foley & Lardner LLP (July 9, 2026).

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