So, what do Venezuela GL 56 & 57 mean?
Background
Venezuela is subject to broad U.S. sanctions, meaning most transactions with the Venezuelan government and its entities are prohibited by default. OFAC issues General Licenses to carve out specific exceptions — activities that are permitted without needing individual approval.
General License 56 — Negotiating Contingent Contracts
The core idea: You’re allowed to negotiate and draft contracts with the Venezuelan government, but you cannot actually execute or perform those contracts until you get separate OFAC approval.
Think of it like being permitted to draw up a deal and shake hands, but the contract only becomes real once a regulator gives the green light.
What’s covered: Any commercial negotiations with any part of the Venezuelan government — ministries, state agencies, state-controlled companies, or anyone acting on their behalf. “Contingent contracts” is defined broadly to include bids, proposals, MOUs, pro forma invoices, and similar preliminary agreements.
Key restrictions — you cannot:
- Negotiate contracts involving Venezuelan or PdVSA (state oil company) bonds or debt
- Use non-standard payment terms — no gold payments, no debt swaps, no Venezuelan digital currency (the “petro”)
- Enforce any legal judgments against blocked Venezuelan assets
- Involve any parties from Russia, Iran, North Korea, or Cuba
- Involve any entity owned or controlled by Chinese interests
- Deal with anyone on OFAC’s SDN (blacklist) list
General License 57 — Financial Services to Certain Venezuelan Banks
The core idea: U.S. financial institutions and service providers can conduct normal financial transactions with or for four specific Venezuelan banks and ordinary Venezuelan government employees.
The four banks covered:
- Banco Central de Venezuela (the central bank)
- Banco de Venezuela
- Banco Digital de los Trabajadores
- Banco del Tesoro
Any entity majority-owned by these banks is also covered.
Also covered: Individual Venezuelan government employees whose assets are technically “blocked” purely because they work for the government — as long as they are not on the SDN blacklist.
What “financial services” means here is defined very broadly: account management, wire transfers, ACH payments, debit/credit cards, digital wallets, remittances, payroll processing, currency exchange, correspondent banking, securities, and more.
Key restrictions:
- This does not unblock any frozen assets
- It doesn’t override any other sanctions rules
- All normal Bank Secrecy Act and anti-money laundering obligations still apply
Practical note for banks: A U.S. financial institution processing these transactions can rely on what the originating or receiving party tells them about compliance — as long as the bank has no reason to suspect something is wrong.
How They Work Together
GL 56 opens a path for businesses to explore and structure deals with Venezuela, while GL 57 enables the banking infrastructure needed to eventually support those deals. Neither license removes the requirement for further OFAC authorization before any real money moves on a new contract.
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