So, I noticed that Russia-related General License 134 listed 10 different sanctions regulations and Executive Orders above the Title. And I was wondering which GL had the next most. Well, turns out that General Licenses 1 through 4 basically are applicable for all the programs (although GL 3 is not incorporated in the DPRK sanctions).

So, I asked for what GL had the next-highest number of impacted sanctions regulatory texts:

Based on a re-evaluation of active General Licenses (GLs) across all OFAC sanctions programs—and excluding the standardized cross-program General Licenses 1, 2, 3, and 4 (which impact over 30 regulations)—the General License with the next-largest number of affected regulatory releases (comprised of specific Executive Orders and 31 CFR parts) is General License No. 5P (Venezuela-Related).

While Russia-Related General License 13I (noted in your link as 134) authorizes transactions prohibited by 5 to 6distinct regulatory citations (specifically Directive 4 under E.O. 14024, E.O. 14066, E.O. 14068, E.O. 14071, and 31 CFR part 587), the Venezuela-related GL series—including GL 5P, GL 9C, and GL 31B—addresses a larger cluster of overlapping Executive Orders.

Selected General License

• License Number: General License No. 5P (and its related series)
• Sanctions Program: Venezuela
• Number of Affected Regulations/Executive Orders:7
  • This General License explicitly authorizes transactions prohibited by 31 CFR part 591 (the Venezuela Sanctions Regulations) and six separate Executive Orders that have been issued to expand the program over time.
  • The affected regulatory releases are: 31 CFR part 591, E.O. 13808, E.O. 13827, E.O. 13835, E.O. 13850, E.O. 13857, and E.O. 13884.
• URL: https://ofac.treasury.gov/media/932786/download?inline

Evaluation Notes:

• Comparison to Russia GLs: The most comprehensive Russia-related wind-down licenses, such as General License No. 102, also list 7 items (31 CFR part 587, E.O.s 14024, 14066, 14068, 14071, and Directives 2 and 4 under E.O. 14024). This ties them with the Venezuela GL series for the highest number of affected releases outside of the humanitarian GLs (1–4).
• Active Status: General License 5P is currently active (authorizing certain transactions related to the PDVSA 2020 8.5 Percent Bond) and is frequently extended. Similarly, GL 31B (Official Business of the IV Venezuelan National Assembly) and GL 9C (Dealings in Certain Securities) remain active and cover the same 7 regulatory items.
• Exclusions: All General Licenses numbered 1, 2, 3, or 4 from any program were excluded from this count per your instructions, as were all archived or expired licenses (such as the original Venezuela GL 44).

Note: I did ask Gemini for the texts of GLs 1-4, because I couldn’t find them. It informed me, unsurprisingly, that these general GLs got incorporated into the text of each program’s sanctions regulations. Older programs periodically get their regulations revised, incorporating at least General Licenses written since the previous revision, so although there is no separate PDF, the regulatory text gets incorporated into the larger document, which, TBH, makes the whole easier to digest.