Mr. Sanctions

Category: General Licenses

  • September 16, 2026: OFAC Update Part 2: Venezuela General License 5 versions goes to Z, and the amended FAQ

    GL 5 has been updated to GL 5Z:

    venezuela_gl5zDownload

    And Frequently Asked Question 595 got updated, too:

    595. What does Venezuela-related General License 5Z authorize?

    Answer

    The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV. Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond. OFAC issued General License (GL) 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.

    General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license. Since that date, OFAC has extended the delay in effectiveness multiple times. Most recently, OFAC issued General License 5Z on September 16, 2026, which further delays the effectiveness of the authorization in GL 5 until November 5, 2026. Between October 24, 2019 and November 5, 2026 (the date the authorization in General License 5Z becomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond. As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.

    To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.

    Date Updated: September 16, 2026

    Date Released

    January 20, 2022

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  • September 14, 2026: OFAC Update, Part 2: New Version of Venezuela GL and updated FAQ

    Today, OFAC updated Venezuela-related General License 52C (Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.):

    venezuela_gl52cDownload

    Additionally, Frequently Asked Question 1245 was updated:

    1245. What activities are authorized by Venezuela General License (GL) 52C, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.”?

    Answer

    GL 52C authorizes, subject to its conditions and exclusions, transactions prohibited by Executive Orders (E.O.s) 13884 or 13850 with Petróleos de Venezuela, S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), by established U.S. entities. Transactions authorized by GL 52C include activities related to:

    • the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan oil or petroleum products of Venezuelan-origin oil and petroleum products;
    • the provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors;
    • entry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products sectors of Venezuela;
    • the formation of new joint ventures or other entities in Venezuela related to such activities; and
    • all transactions ordinarily incident and necessary to such activities, including the performance of commercial, legal, technical, safety, and environmental due diligence and assessments related to the foregoing.

    GL 52C also authorizes individuals blocked pursuant to the Venezuela Sanctions Regulations (VSR) to execute and sign contracts authorized by GL 52C in their official capacity as officers, employees, or authorized representatives of PdVSA or PdVSA Entities.

    Notably, GL 52C does not authorize transactions that would otherwise be prohibited by the VSR and associated Executive Orders, including E.O. 13808 and E.O. 13835, such as:

    • transactions related to bonds and debt issued by PdVSA and its subsidiaries, including settlement of such bonds and debt;
    • transactions involving equity interest in PdVSA and its subsidiaries, including the sale, transfer, assignment, or use as collateral of equity interests in PdVSA and its subsidiaries by the Government of Venezuela;
    • transactions involving the transfer of equity interest in PDV Holding, CITGO Holding, or CITGO Petroleum Corp.;
    • transactions to affect or alter the governance of PDV Holding, Inc., Citgo Holding, Inc., or CITGO Petroleum Corporation, including the appointment, removal, or replacement of any director, officer, or other corporate governance official; or
    • transactions involving any other individuals or entities on the List of Specially Designated Nationals and Blocked Persons.

    GL 52C also does not authorize:

    • transactions that are not on commercially reasonable terms;
    • payment in gold or the use of debt swaps;
    • payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
    • any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled by or in a joint venture with such persons;
    • transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
    • the unblocking of any property blocked pursuant to the VSR; or
    • any transaction involving a blocked vessel.
    Date Updated: September 14, 2026

    Date Released

    March 18, 2026

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  • September 10, 2026: ECJU updates OGL, adds OGEL for defence exports

    ECJU - BIST final

    New and updated ECJU General Licences for defence export collaboration

    The Export Control Joint Unit (ECJU) has updated the Open General Licence (Global Combat Air Programme) and introduced a new Open General Export Licence (Agreement on Defence Export Controls ‘De-Minimis’ Exports).

    These measures support defence collaboration with close international partners by providing simplified licensing arrangements while maintaining the UK’s robust export controls. Details on the new measures can be found in the Notice to Exporters linked below. 

    The following are now available on GOV.UK:

    Contact ECJU for queries about strategic export licensing via email at exportcontrol.help@businessandtrade.gov.uk 

    Here’s the Notice to Exporters:

    Notice

    NTE 2026/19: Updated OGL (Global Combat Air Programme) and new OGEL: Agreement on Defence Export Controls ‘De-Minimis’ Exports

    Published 9 September 2026

    Introduction

    The Export Control Joint Unit (ECJU) has updated the existing GCAP Open General Licence and introduced a new Open General Export Licence for the Defence Export Controls Agreement.

    Both measures aim to support defence collaboration with close partners and provide simplified licensing arrangements, while maintaining the UK’s robust export controls.

    Exporters should review the relevant licence carefully and ensure that they can comply with all applicable terms and conditions before using it. Where the conditions of either licence cannot be met, exporters may use an alternative licensing route.

    Updated Open General Licence (Global Combat Air Programme)

    The Global Combat Air Programme (GCAP) is a joint programme between the UK, Japan and Italy to develop a next-generation combat aircraft.

    The previous GCAP Open General Licence (OGL), first published in August 2024, has been updated to reflect the programme’s progression into its next phase of development. The amendments:

    • add Supply Chain Nations
    • provide for authorised Observer Nation activities
    • update programme terminology

    Read the updated Open General Licence (Global Combat Air Programme)

    Subject to its conditions, the updated OGL permits the export and transfer of specified dual-use and military goods, software and technology to GCAP Partner Nations and GCAP Supply Chain Nations where those activities are necessary to support the development, production, test and evaluation, through-life support, use, disposal or decommissioning of GCAP. The licence also permits limited, authorised activities relating to Observer Nations.

    The previous GCAP OGL, dated August 2024, has been revoked and replaced by this updated licence. Existing registrations remain valid.

    Exporters should review the updated licence carefully and ensure they can comply with all the terms and conditions before using it.

    New Open General Export Licence: Agreement on Defence Export Controls ‘De-Minimis’ Exports

    Read the new Open General Export Licence: Agreement on Defence Export Controls ‘De-Minimis’ Exports

    This OGEL supports the UK’s implementation of the ‘de-minimis’ provisions contained in Article 3 of the Agreement on Defence Export Controls between the UK, France, Germany and Spain.

    The ‘de-minimis’ provisions apply where the value of UK-origin goods, software or technology does not exceed 20% of the total value of the final system into which they are to be integrated.

    The licence permits exports and transfers of specified military goods, software and technology to Partner Nations (France, Germany and Spain) for integration into a final system, where the total UK-origin content of that system does not exceed the ‘de-minimis’ threshold, and where that final system is to be transferred or exported from a Partner Nation to any destination not excluded by the licence.

    Exporters should review the licence carefully and ensure they can comply with all the terms and conditions before using it.

    Registration and guidance

    Before using these licences, exporters must register through SPIRE. This includes stating where you will keep records of the exports or transfers, and where ECJU may inspect them.

    Further information:

    Declaration requirements

    As outlined in Notice to exporters 2026/13, when exporters register to use OGELs or GEAs, they are given a unique licence reference in the following format: ‘GBOGE20XX/XXXXX’.

    For relevant exports, this code should be input into the UK’s Customs Declarations System (CDS), which includes a field where this licence reference can be entered.

    Including the licence reference on CDS will bring goods exports made under OGELs and GEAs into line with standard individual export licences (SIELs) and open individual export licence (OIELs). The roll-out of this requirement across all relevant OGELs aims to deliver data that will help us maintain the appropriate balance between transparency and administrative burden, while providing insight into OGEL usage and trends.

    Contact ECJU 

    General queries about strategic export licensing 

    Export Control Joint Unit 
    Department for Business and Trade 
    Old Admiralty Building 
    Admiralty Place 
    London 
    SW1A 2DY 

    Email exportcontrol.help@businessandtrade.gov.uk 

    Telephone 020 7215 4594

    the updated Open General Licence (OGL):

    Open-General-Licence-Global-Combat-Air-ProgrammeDownload

    the new Open General Export Licence (OGEL):

    Open-General-Export-Licence-de-minimis-exports-treaty-on-defence-exportsDownload

    and the updated guidance:

    Guidance

    Guidance on Agreement on Defence Export Controls

    Updated 9 September 2026

    Overview

    This guidance provides background on the Agreement on Defence Export Controls and sets out the requirements for licence applications to be considered against Articles 1, 2 or 3 of the agreement.

    The Agreement on Defence Export Controls (the agreement) is a treaty between Germany, France, Spain, and the UK (the signatory states). The UK acceded to this agreement in December 2025. It aims to reduce the administrative burden for exports or transfers of defence related products and supports industrial partnerships between the signatory states.

    There are 3 key articles covering different aspects of co-operation under the agreement, which only applies to items on the Common Military List. There are only minor differences between the Common Military List and the UK Military List.

    Key articles of the agreement

    Article 1

    Article 1 covers defence exports related to joint intergovernmental programmes, between 2 or more signatory states, formalised through memoranda of understanding (MoUs) or intergovernmental agreements. Article 1 can apply to both new and existing programmes. In the UK, it will be the relevant Ministry of Defence (MOD) team who will confirm and identify programmes falling under Article 1.

    The principle of Article 1 is that a signatory state should not oppose an export or transfer to a third party, which is requested by another signatory state, other than in exceptional situations in which that transfer or export compromises its direct interests or national security. The agreement requires any concerns with any such export to be raised with the other contracting parties within 2 months.

    Article 2

    Article 2 facilitates exports and transfers arising from industrial co-operation projects that promote closer integration of defence industries across the signatory states.

    Article 2 establishes a 2-step process to facilitate exports and transfers between industrial partners involved in recognised co-operation projects. Its aim is to reduce the export control burden for defence-related products developed through collaborative efforts.

    Step 1: project recognition

    The first step is for the relevant signatory states to consider and agree that a specific industrial co-operation project qualifies under Article 2. This requires a coordinated submission of a project file by the industrial partners to their respective national authorities. In the UK, the MOD is responsible for assessing this project file and confirming project eligibility.

    Further advice on project recognition will be provided in due course.

    Step 2: export licensing

    Once a project is recognised, licence applications are assessed in accordance with Article 2. While Article 2 seeks to reduce the export licensing burden, it does not exempt exporters from submitting licence applications for transfers to industrial partners.

    The principle of Article 2 is that, in relation to a defence product developed by defence manufacturers in 2 or more signatory states, a signatory state shall not oppose the export or transfer by a manufacturer of another signatory state to a non-state party, other than in exceptional situations in which that transfer or export compromises its direct interests or national security.

    The agreement requires any concerns with any such export to be raised with the other contracting parties within 2 months from the date on being informed of the proposed transfer or export.

    Note, the decision to grant or refuse the licence for the export of the final product shall fall to the signatory state from whose territory that export is carried out. Those decisions do not fall within the scope of Article 2.

    Article 3

    Article 3 implements a de minimis principle which applies when the value of defence-related components from one or more signatory states in a final system exported by another signatory state is below 20%. It does not apply to exports covered by Articles 1 or 2.

    The de minimis principle applies when the value of defence-related components from one or more signatory states in a final system exported by another is less than 20% of the total value of that system. The final integrator will be responsible for assessing the overall contribution from each signatory state. They will take into consideration each of its direct suppliers representing over 2% of the total final value the products which that supplier procured directly from a contracting party concerned.

    Note, the total value excludes maintenance, spare parts, training, and repairs.

    Under the agreement, an end-user undertaking is not required to support an export licence application submitted for consideration under Article 3. Instead, a harmonised ‘Integration Certificate’ has been developed, which provides information on the goods and parties involved, end user details and a de minimis declaration on the value of defence-related products from a supplying signatory state to be integrated into the final system in another signatory state.

    While Article 3 applies to items on the Common Military List, certain goods are excluded from this principle, as listed in Annex 3 of the agreement. Detailed guidance on Article 3 is included in Annex 2 of the agreement. A worked example on the de minimis principle is provided within the guidance on completing the Integration Certificate.

    Open General Export Licence (OGEL)

    An Open General Export Licence (Agreement on Defence Export Controls: ‘De-Minimis’ Exports) has been published to support eligible exports under Article 3.

    This may remove the need for an individual licence application where the export is within scope and the exporter can comply with all the OGEL terms and conditions, including the Article 3 de minimis requirements.

    Where the OGEL does not apply, you should submit an individual licence application.

    Submitting licence applications for consideration under the agreement

    All applications submitted for consideration under the agreement will continue to be assessed in the usual way against the Strategic Export Licensing Criteria.

    Applications under Article 1: intergovernmental programmes

    When submitting licence applications for consideration under Article 1

    • the ‘intended end use of the products’ field in the licence application form should begin with ‘URGENT, for consideration under Article 1 of the Defence Exports Agreement’
    • if the ultimate end user(s) of the end products in a third country is known, they must be identified in the licence application

    Under the principles of Article 1, we will not normally refuse applications for export to a signatory state, apart from in an exceptional situation which compromises our direct interests or our national security.

    If we identify any such concerns, we will consult with other signatory states before making a final decision.

    Applications under Article 2: industrial co-operation

    When submitting licence applications for consideration under Article 2:

    • the ‘intended end use of the products’ field in the licence application form should begin with ‘URGENT, for consideration under Article 2 of the Defence Exports Agreement’
    • identify the ultimate end user if known
    • reference previous licences that enabled technology transfers under ‘previous applications’
    • clearly state the final products into which UK items will be integrated under ‘intended end use’
    • ensure all information aligns with the scope of the agreed project
    • attach the joint project descriptive file and confirmation of project eligibility

    Applications that are not properly marked or which do not contain the required information will not be considered under Article 2 and will be processed as a standard licence request.

    Under the principles of Article 2, we will not normally refuse applications for export to a signatory state, apart from in an exceptional situation which compromises our direct interests or our national security.

    If we identify any such concerns, we will consult with other signatory states before making a final decision.

    Exports of final products from an industrial co-operation project

    The decision to approve or refuse a licence to export the final product lies with the signatory state from whose territory the export takes place. This decision is outside the scope of Article 2.

    Export licence applications for export of a final product should not be marked for consideration under Article 2 and will not be assessed as such.

    However, the UK will notify authorities in the relevant signatory states if it refuses a licence for a system produced through recognised co-operation that includes components authorised for re-export by signatory states.

    To support this, UK exporters should identify, in the ‘intended end use of the products’ field in their licence application, that this application relates to a final product from an industrial co-operation project under Article 2 of the Defence Exports Agreement, and identify which signatory states were involved in the development of the final product.

    Licences relating to a recognised co-operation

    Certain exports or transfers – such as those involving technology, tools, or production line setup – may be necessary to implement co-operation but are not linked to a given export or transfer to a non-signatory state.

    To facilitate the processing of such licence applications, exporters should include the relevance to the agreed Article 2 industrial co-operation and the joint project descriptive file with the licence application.

    Applications under Article 3: de minimis principle

    Open General Export Licence (OGEL)

    For exports related to Article 3, exporters should first check whether the Open General Export Licence (Agreement on Defence Export Controls: ‘De-Minimis’ Exports) applies. If the OGEL applies, exporters must register to use it and comply with its terms and conditions.

    Individual Export Licence Applications

    Where the Open General Export Licence (Agreement on Defence Export Controls “De-Minimis” Exports) does not apply, exporters should submit an individual export licence application for consideration, for example standard individual export licences (SIELs).

    For the application to be considered under Article 3, the ‘intended end use of the products’ field in the licence application form should begin with ‘URGENT de minimis, for consideration under Article 3 of the Defence Exports Agreement’.

    If the application is not properly marked or contains the required information, it will not be considered against Article 3 and will be processed as a standard licence request.

    If the de minimis principle applies:

    • no end-user undertaking is required for exports to a signatory state
    • an integration certificate may be requested to confirm incorporation into the final system
    • we will assess the application without delay

    Under the principles of Article 3, we will not refuse applications apart from in an exceptional situation which compromises our direct interests or our national security. If the third-party recipient of the final system is unknown at the time of licensing, the signatory state exporting the system will be solely responsible for assessing that export once the recipient is identified.

    Applicants must ensure the following:

    • the proposed export is not listed in Annex 3 exclusions
    • the first recipients are in a signatory state to the agreement
    • the application concerns defence-related products that will be integrated into a final system in a signatory state and then remain in a signatory state or be exported from a signatory state to a non-signatory state

    The application must include supporting documentation specifying:

    • confirmation that the equipment is not excluded under Annex 3
    • the maximum value share of UK components (excluding maintenance, spare parts, training and repairs) in the final system, specifying whether it is below 20%
    • a description of the final system, including its Military List (ML) classification
    • identification of the first integrator and consignee (if known) responsible for exporting the final system
    • identification of the final consignee(s) of the integrated system
    • details of any items not covered by the de minimis rule

    Integration certificate

    Signatory states may request a certificate confirming integration of the product into the final system before transfer. Where a UK entity is the final integrator, they will need to complete the integration certificate. A template certificate is available on GOV.UK, for which there is separate guidance.

    Exports of final products from the UK

    The decision to approve or refuse a licence for exporting the final product lies with the signatory state from whose territory the export occurs. This decision is outside the scope of Article 3.

    English language version of the agreement

    View an English language version of the Agreement on Defence Export Controls.

    Guidance on completing the Integration Certificate

    View guidance on completing the Integration Certificate and a template of the certificate.

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  • September 8, 2026: OFAC Update, Part 2: Iran and Counter-Terror GL changes

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is implementing the following actions with regard to its Iran sanctions programs:

    Counter-Terrorism GL 37:

    ct_gl37Download

    The Suspension Notice:

    notice_of_suspension_iran_09082026Download

    Iran GL J-1:

    iran_glj_1Download

    Iran GL DD:

    iran_gl_ddDownload

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  • September 4, 2026: OFAC Update, Part 2: New Iran-related Wind-Down General License

    It’s GL CC (Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on September 4, 2026):

    iran_gl_ccDownload

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  • September 3, 2026: OFAC Update, Part 2: new version of Cuba General License 4

    This is GL 4A (Authorizing Transactions for Third-Country Diplomatic and Consular Missions in Cuba):

    cuba_gl4aDownload

    What are the important differences? Let Claude explain:

    Paragraph (c) – restructured and narrowed:

    • GL 4 had two exclusions: (c)(1) barred financial transfers to any blocked person except for taxes, fees, import duties, or permits/licenses/public utility services tied to paragraph (a) transactions; and (c)(2) barred unblocking of any property.
    • GL 4A drops (c)(1) entirely. The sole remaining exclusion is the unblocking prohibition (what was (c)(2)), now written as the whole of (c).

    Practical effect (my reading, not stated in the text itself): By removing (c)(1)’s narrow carve-out, GL 4A appears to broaden the scope of authorized financial transfers to blocked persons. Under GL 4, such transfers were confined to taxes, fees, import duties, and permit/license/utility payments tied to official-business transactions. Under GL 4A, that specific limitation is gone – transactions otherwise meeting the “ordinarily incident and necessary” standard in (a) or (b) are no longer subject to that narrower financial-transfer restriction. The only thing GL 4A still expressly withholds is unblocking of property. 

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  • September 2, 2026: Finally – OFAC reminds you of the ARBP filing, issues new versions of Venezuela GLs, and amends a related FAQ

    Reminder to file the 2026 Annual Report of Blocked Property; Issuance of Amended Venezuela-related General Licenses and Frequently Asked Question

    09/02/2026

    Recent Actions Body

    On July 1, 2026, the Office of Foreign Assets Control (OFAC) issued a recent actions notice, reminding U.S. persons holding blocked property as of June 30, 2026, to file an Annual Report of Blocked Property (ARBP) no later than September 30, 2026. Failure to file the ARBP by September 30 may lead to an enforcement referral.

    For additional information, please review OFAC’s Guidance on Filing the 2026 Annual Report of Blocked Property.

    Additionally, OFAC is issuing Venezuela-related General License 51D, “Authorizing Certain Activities Involving Venezuelan-Origin Coal or Minerals, Including Gold;” Venezuela-related General License 54C, “Authorizing the Supply of Certain Items and Services for Coal or Minerals Operations in Venezuela;” and Venezuela-related General License 55A, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Coal or Minerals Sectors.”

    Lastly, OFAC has amended one Venezuela-related Frequently Asked Question, FAQ 1247.

    The guidance:

    arbp_guidance_2026Download

    GL 51D:

    venezuela_gl51dDownload

    GL 54C:

    venezuela_gl54cDownload

    GL 55A:

    venezuela_gl55aDownload

    and the FAQ:

    1247. Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46D, 51D, and 52B? 

    No, provided that non-U.S. persons comply with certain conditions outlined in GLs 46D, 51D, and 52B as described below. Subject to certain conditions, GLs 46D, 51D, and 52B authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), as well as certain transactions with the Government of Venezuela, including Carbones del Zulia S.A. (Carbozulia), PdVSA, or CVG Compania General de Mineria de Venezuela CA (Minerven) that are ordinarily incident and necessary to, among other activities, the exportation, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin oil, petrochemical products, minerals (including gold), or coal. Generally, non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized under GLs 46D, 51D, and 52B — such as transacting with PdVSA or importing Venezuelan-origin oil, petrochemical products, minerals, or coal, into a third country — provided that:

    • The non-U.S. entity was organized under the laws of a third country on or before January 29, 2025;
    • Any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, 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;
    • The payment terms are commercially reasonable;
    • The payment terms do not involve debt swaps, and are not denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
    • The transaction does not involve a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;
    • The transaction does not involve an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
    • The transaction does not involve a blocked vessel; and
    • With respect to GL 51D, the transaction does not involve the processing or refining of Venezuelan-origin coal or minerals, including gold, in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or the People’s Republic of China.

    These conditions are designed to ensure that transactions involving the Government of Venezuela, including Carbozulia, PdVSA, Minerven, or Venezuelan-origin oil, petrochemical products, minerals, or coal occur through legitimate and authorized channels, consistent with efforts to restore prosperity, safety, and security to Venezuela. Non-U.S. persons who continue to transact with PdVSA or Minerven, or import Venezuelan-origin oil, petrochemical products, minerals including gold, or coal, without complying with the above conditions risk being designated themselves, including for providing financial, material, or technological support to blocked persons, being responsible for or complicit in a transaction involving deceptive practices or corruption and the Government of Venezuela, or operating in the gold or oil sectors of the Venezuelan economy.

    Please note that GL 52B contains additional restrictions on engaging in certain transactions prohibited by other Venezuela-related Executive orders, such as transactions related to bonds and debt issued by PdVSA, as well as on the entry into a settlement agreement or the enforcement of any lien, judgment, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property of any persons blocked pursuant to the Venezuela Sanctions Regulations.

    Please see FAQ 1226 for the definition of “Venezuelan-origin oil,” which includes petroleum products.

    Please see FAQ 1232 for what OFAC considers “commercially reasonable terms.”

    Please see FAQ 1239 for information on how to make authorized payments to the Foreign Government Deposit Funds, as specified in E.O. 14373.

    Date Updated: September 02, 2026

    Updated on Sep 02, 2026

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  • August 27, 2026: Got Wite-Out? OFAC issues new versions of 8 Venezuela General Licenses, issues 2 new FAQs, amends 2, and archives 1 – and Claude explains the changes

    Issuance of Amended Venezuela-related General Licenses and Associated Frequently Asked Questions

    Release Date

    08/27/2026

    Recent Actions Body

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Venezuela-related General License 46D, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;” Venezuela-related General License 47B, “Authorizing the Sale of U.S.-Origin Diluents to Venezuela;” Venezuela-related General License 48C, “Authorizing the Supply of Certain Items and Services to Venezuela;” Venezuela-related General License 50C, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities;” Venezuela-related General License 51C, “Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold;” Venezuela-related General License 52B, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.;” Venezuela-related General License 54B, “Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela;” and Venezuela-related General License 61A, “Authorizing the Supply of Certain Items and Services to Venezuela Related to Telecommunications.”

    Additionally, OFAC is issuing two new Venezuela-related Frequently Asked Questions (FAQs 1267 and 1268), amending two Venezuela-related Frequently Asked Questions (FAQs 1233 and 1244), and archiving FAQ 1260.

    Claude explains the difference:

    What’s new is that OFAC fully removed the separate governing-law requirement, the clause requiring contract terms to be “construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States.” So the two conditions that used to travel together (US governing law + dispute resolution venue) have been decoupled, and only the dispute-resolution piece survives. That’s the substantive change behind your two new FAQs:

    • FAQ 1267 (new): Asks whether the amended GLs still require a choice-of-law provision. Answer: no, effective Aug 27, 2026. OFAC states the rationale as responding to “investment-related reforms made by the GOV since January 2026.” It doesn’t name Venezuela’s Hydrocarbons Law amendment specifically, so connecting the two is my inference based on outside reporting, not something OFAC states in the FAQ itself.
    • FAQ 1268 (new): Confirms the dispute-resolution-venue requirement itself is untouched, and adds a clarifying line that the requirement “relates to the jurisdiction in which dispute resolution proceedings must occur, rather than the law governing the underlying contract.”

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  • August 26, 2026: OFAC Update, Part Two: Russia (new version) and Counter-Terror (new) General Licenses

    First, Counter-Terrorism GL 36 (Authorizing the Wind Down of Transactions Involving Autistici Inventati):

    ct_gl36Download

    Second, Russia GL 104B (Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068):

    russia_gl104b_0Download

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  • Burning Question: How New Is “New” in Operation Economic Outcast?

    I asked Claude the following this evening:

    Attached is today’s State Department Fact Sheet on “Operations Economic Outcast” and Treasury’s related press release. Also attached are Treasury Secretary Bessent’s related remarks. Look at these, and any 3rd party news and commentary pieces on today’s OFAC action. Summarize what happened, and analyze the short-term and longer-term implications of these actions. What is substantive, and what is rhetorical? Are there measures that will be implemented in the really near future, such that US consumers and voters are likely to see tangible benefits from these actions by Election Day in November 2026? Add any other commentary you find that adds to the overall picture. Check all that you write against the sources you use – and correct anything that is not well-supported by the sources. List the sources at the end. No hallucinations, please. Write this for an audience that has interest in US politics and the economy, but is not necessarily well-versed in sanctions except in the most basic way – so write accordingly.

    And here is Claude’s analysis of yesterday’s Iran sanctions actions and rhetoric – with some significant pushback from me on some elements that Claude initially thought too much of:

    Treasury and State spent August 24 rolling out “Operation Economic Outcast” with the kind of language usually reserved for military campaigns: an “economic D-Day,” a “zero leakage” approach, nearly 60 new entries on the SDN list, and five new sectoral determinations under Executive Order 13902 covering digital assets, technology, gold, aviation, and shipping. Secretary Bessent framed it as the start of a sustained campaign to collapse every remaining option for Tehran.

    That’s a lot of rollout. The burning question is how much of it is actually new, once you get past the press conference and into the designation text itself.

    The determinations nobody used

    Start with the five sectoral determinations, since that’s where the branding worked hardest. E.O. 13902 isn’t a new authority. Trump signed it in January 2020 to cover construction, mining, manufacturing, and textiles. Treasury added the financial sector that October. Petroleum and petrochemicals followed in October 2024. Digital assets, technology, gold, aviation, and shipping are the fourth round of sector additions to an order that’s now six and a half years old.

    That history matters for a second reason beyond age. Iran and the Government of Iran are already subject to a comprehensive US embargo under the ITSR. A sectoral determination adds nothing to what a US person is already barred from doing with Iran directly. Its entire function is secondary sanctions exposure for non-US persons. That works by giving OFAC an easier evidentiary path, operating in the sector rather than proving a specific significant transaction, to reach someone who isn’t otherwise within US jurisdiction. Whether a determination matters in practice depends entirely on whether OFAC designates anyone under it.

    So who did OFAC designate today under the five new sectors? Nobody. Every one of the roughly 60 new entries in the State Department fact sheet and the Treasury press release cites an authority that predates this week.

    AuthorityWhat it coversUsed for today’s designations?
    E.O. 13382 (2005)WMD and missile proliferationYes, the Hong Kong/China procurement network supporting Malek Ashtar University, the BRE Line logistics network
    E.O. 13694, as amended (2015 onward)Malicious cyber activityYes, the six individuals tied to Iran’s Ministry of Intelligence and Security
    E.O. 13224, as amended (2001)CounterterrorismYes, Mohammad Ahmed Suhil Fattouh, Ivan Obukhov, and their shipping vehicles
    E.O. 13902, financial sector determination (Oct. 2020)Iran’s financial sectorYes, the shell companies tied to Bank Melli’s shadow banking network
    E.O. 13902, petroleum sector determination (Oct. 2024)Iran’s petroleum and petrochemical sectorYes, the shadow fleet vessels and owners, the Wellbred trading network
    E.O. 13949 (2020)Conventional armsYes, the seven Iranian military officials named by State
    E.O. 13846 (2018)JCPOA reimposition, petroleum tradeYes, the petrochemical traders named by State
    E.O. 13902, the five sectors added Aug. 24, 2026Digital assets, technology, gold, aviation, shippingNo

    Five new sectors, zero new designees. That’s worth sitting with, because it’s a useful diagnostic for reading any Treasury rollout of this size. The announced legal architecture and the actual designation list are two different documents, and they don’t have to move together. A determination is Treasury giving itself a faster path to designate people operating in a sector. It isn’t a designation. Until OFAC puts a name under one of the five new sectors, the practical effect on Iran’s economy from that piece of Monday’s announcement is exactly zero, no different from the day before the press conference.

    There’s a comparison worth keeping in mind for judging how much these five sectors could eventually matter. When Treasury added the financial sector to E.O. 13902 in October 2020, analysts flagged it at the time as functionally close to a full embargo, since almost any transaction with an Iranian counterparty eventually touches Iran’s banking system somewhere. A narrower sector, like textiles or mining, only closes off that one line of business, and a counterparty can just trade in something else. Of this week’s five, shipping and gold probably have that kind of financial-sector-style reach, since they sit close to how Iran actually moves and stores value. Digital assets and technology are narrower by comparison, and aviation narrower still. None of that is testable yet. It’s a question about which sector Treasury reaches for first, once it reaches for any of them. Bessent told reporters he expects Treasury to designate a major financial institution later this week. Whether that designation cites one of Monday’s five new sectors, rather than the financial sector determination that’s already existed since 2020, is the detail worth checking when it happens.

    What the general license suspensions actually touch

    The other piece of Monday’s announcement billed as tightening the screws is the suspension of several general licenses. The Treasury release describes them as licenses that had authorized certain remittance payments to Iran and Iranian access to the US cultural and academic system. OFAC’s own recent actions listing for August 24 confirms Iran General License G, the academic exchange license in place since 2014, covering university exchange agreements, scholarships, and the administration of entrance exams for Iranian applicants, along with a license covering professional and amateur sports exchanges. Trade press reporting also has the personal, noncommercial remittance license under 31 CFR 560.550 suspended, with a wind down running through roughly September 8 under a newly issued General License BB.

    That’s a real change for the people who use those licenses. It isn’t a real change for the IRGC or for regime leadership, and the reason is built into how the licenses were written. General licenses covering personal remittances and academic exchange exist because they were carved out of the comprehensive embargo for individuals and civil society. As a matter of standard OFAC drafting, that class of license already excludes the Government of Iran and any blocked person from using it. The IRGC was never moving money through a remittance channel covered by GL 560.550, and regime officials weren’t the ones administering entrance exams under GL G. The population that loses access when these licenses come off the board is Iranian civilians receiving money from family abroad, and Iranian students, researchers, and athletes trying to participate in exchange programs. Regime and IRGC finance runs through exchange houses, shadow banking networks, gold, and crypto, the same channels the new designations and the sectoral determinations are aimed at, not through a university scholarship program.

    That’s a real tension in how Monday’s action describes itself. The stated target throughout is the regime and its enablers. The general license suspensions land somewhere else, on ordinary Iranians and on the people-to-people channels Iran sanctions programs have historically tried to preserve even during periods of maximum pressure, not on the regime the campaign says it’s targeting.

    What this adds up to

    None of this makes Monday’s action empty. Roughly 60 new SDN entries is a real expansion of target lists in networks already under scrutiny: the Hong Kong and China procurement chains, the shadow fleet, the MOIS cyber cluster, the oil brokerage networks running through the UAE and Singapore. Those designations use existing, well-tested authorities. They carry the consequences designations ordinarily carry:

    • Blocked property in the United States or in the hands of US persons
    • Correspondent banking exposure for foreign financial institutions that keep dealing with the newly listed parties
    • A paper trail other governments and banks will have to account for in their own due diligence

    The two pieces of Monday’s announcement built to sound the most unprecedented are the five new sectors and the general license suspensions. They’re also the two doing the least actual work right now. The determinations haven’t been used yet. The license suspensions hit civilians rather than the regime they’re framed as targeting. That’s a pattern worth checking for in any sanctions rollout that leans hard on scale and language. Look at what got designated under the headline new authority before assuming the headline new authority did anything. If Treasury designates a bank or a shipping registry under the aviation or shipping determination in the coming weeks, that’s the moment the unprecedented framing starts to earn itself. Until then, it’s capacity, not action.

    Source verification

    Sources checked directly: the State Department fact sheet and the Treasury press release announcing Operation Economic Outcast, both dated August 24, 2026; Secretary Bessent’s prepared remarks from the same day; and OFAC’s own recent actions listing for August 24, 2026, which confirms the suspension of Iran General License G and the sports and cultural exchange license. Every legal basis cited above for the roughly 60 new designations was checked against the authority codes in the two primary announcements rather than assumed. The E.O. 13902 sector determination history (2020 construction, mining, manufacturing, and textiles; October 2020 financial sector; October 2024 petroleum and petrochemicals) is confirmed against OFAC FAQ 831 and contemporaneous client alerts from that period. The personal remittance general license under 31 CFR 560.550 and the General License BB wind down window were reported by trade press covering the rollout and have not yet been independently pulled from OFAC’s own general license text. Treat that specific detail as reported rather than primary source confirmed until the underlying license is checked directly.

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