Mr. Sanctions

Category: New General License Version

  • October 21, 2026: OFAC Update, Part 2: New Iran-related wind-down General Licenses, new versions of Russia-related General License and related Frequently-Asked Questions

    Two new Iran-related wind-down GLs – GG (Authorizing the Wind Down of Transactions Involving Karnakis and Karnakis):

    iran_gl_ggDownload

    and HH (Authorizing Wind Down Activities, Limited Safety and Environmental Transactions, and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on October 21, 2026):

    iran_gl_hhDownload

    and Russia-related GL 131 is now version K (Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities):

    russia_gl131kDownload

    and there are updated versions of FAQ 1224:

    1224. What negotiations does Russia-related General License 131K authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

    Answer

    On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131K, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131Kexpires on November 21, 2026.

    GL 131K does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131K must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war.

    As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.

    OFAC may revoke GL 131K at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.

    Date Updated: October 21, 2026

    Date Released

    November 19, 2025

    and FAQ 1225:

    1225. What activities do Russia-related General License 128D and General License 131K authorize related to Lukoil International GmbH (LIG)?

    Answer

    OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128D and GL 131K. The GLs are similar but have different expiration dates and terms as each serves a different purpose.

    • To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. OFAC subsequently issued GL 128C and GL 128D to extend the existing authorization until April 24, 2027.
    • To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B, 131C, 131D, GL 131E, GL 131F, GL 131G, GL 131H, GL 131I, GL 131J, and GL 131K to extend the existing authorization until November 21, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

    GL 128D and GL 131K expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128D and GL 131K. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128D and GL 131K authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.

    Both GL 128D and GL 131K also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

    Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128D and GL 131K. Similarly, non-U.S. persons may rely upon GL 128D and GL 131Kregardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128D and GL 131K, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

    Date Updated: October 21, 2026

    Date Released

    December 4, 2025

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  • October 16, 2026: OFAC updates Venezuela General License 60, and a related Frequently Asked Question

    The amended GL is 60A (Authorizing Transactions Related to Earthquake Relief Efforts in Venezuela):

    venezuela_gl60aDownload

    and FAQ 1263:

    1263. Does General License (GL) 60A require that payments to the Government of Venezuela be made into the Foreign Government Deposit Funds Account (FGDF)?

    Answer

    No. GL 60A authorizes all transactions related to earthquake relief efforts in Venezuela under the Venezuela Sanctions Regulations, which includes payment of taxes, tolls, and fees to the Government of Venezuela connected with such relief efforts. Payments related to earthquake relief that are authorized by GL 60A do not need to be paid into the FGDF.

    However, the requirements under other Venezuela-related GLs, such as GLs 46E, 48C, 49B, 50C, 51D, 52C, and 54C, remain in place. Payments for activities outside of the scope of GL 60A but authorized under other Venezuela-related GLs that contain the FGDF payment requirement must continue to be paid into the FGDF and may not be recharacterized as earthquake relief or otherwise modified for the purpose of avoiding payment into the FGDF.

    Date Updated: October 16, 2026

    Date Released

    July 17, 2026

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  • October 15, 2026: OFAC Update, Part 2: New and Updated GLs and FAQs

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 128D, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia;” and Russia-related General License 130B, “Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria.”

    Additionally, OFAC is issuing Iran-related General License FF, “Authorizing the Wind Down of Transactions Involving International Development Bank for Investment and Finance.”

    OFAC is also issuing one new, Cuba-related Frequently Asked Question (FAQ 1276), and one amended, Russia-related Frequently Asked Question (FAQ 1225).

    Here are the FAQs – the two Russian ones:

    russia_gl128dDownload

    and

    russia_gl130bDownload

    and the Iran one:

    iran_gl_ffDownload

    and the FAQs – the Cuba one:

    1276. On October 15, 2026, the Department of State designated the Banco Internacional de Comercio, S.A. (BICSA) pursuant to Executive Order (E.O.) 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with BICSA?

    Answer

    The U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the divestment from or the wind down of transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly, a 50 percent or greater interest, through November 14, 2026. However, non-U.S. persons, including FFIs, should proceed with caution in any dealings with a party sanctioned under this authority. Actions to return assets to a sanctioned party or transfer them to another jurisdiction for potential use by the target could expose non-U.S. persons to significant sanctions risk.

    Foreign persons unable to divest from or wind down transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly, a 50 percent or greater interest, before November 14, 2026, are encouraged to contact the OFAC Compliance Hotline.

    Persons subject to U.S. jurisdiction, including U.S. persons and entities owned or controlled by U.S. persons, should additionally note that this limited non-targeting posture does not authorize any transaction prohibited by the Cuban Assets Control Regulations (CACR), 31 CFR part 515, or any other OFAC sanctions authority. Persons subject to U.S. jurisdiction have long been prohibited from transacting with BICSA, a Cuban State-Owned entity, absent OFAC authorization. Accordingly, persons subject to U.S. jurisdiction continue to be prohibited from engaging in transactions involving BICSA, including in connection with a non-U.S. person’s wind down of activities with BICSA, unless separately authorized by OFAC. Relevant authorizations may include humanitarian and diplomatic-related transactions authorized under the CACR in subpart E of part 515 and under E.O. 14404 via General License (GL) 1 and GL 4A. For additional information on GL 1, see FAQ 1253.

    Date Released

    October 15, 2026

    and the Russia one:

    1225. What activities do Russia-related General License 128D and General License 131Jauthorize related to Lukoil International GmbH (LIG)?

    Answer

    OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128D and GL 131J. The GLs are similar but have different expiration dates and terms as each serves a different purpose.

    • To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. OFAC subsequently issued GL 128C and GL 128D to extend the existing authorization until April 24, 2027.
    • To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B, 131C, 131D, GL 131E, GL 131F, GL 131G, GL 131H, GL 131I, and GL 131J, to extend the existing authorization until October 22, 2026. Please see Frequently Asked Question 1224for additional information on authorizations regarding negotiations for the sale of LIG Entities.

    GL 128D and GL 131J expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128D and GL 131J. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128D and GL 131J authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.

    Both GL 128D and GL 131J also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

    Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128D and GL 131J. Similarly, non-U.S. persons may rely upon GL 128D and GL 131J regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128D and GL 131J, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

    Date Updated: October 15, 2026

    Date Released

    December 4, 2025

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  • October 8, 2026: OFAC Update, Part 2: New Iran Wind-Down General License, and an amended Russian one

    The new one is Iran-related GL EE (Authorizing the Wind Down of Transactions Involving Samudra Marine Services Private Limited):

    iran_gl_eeDownload

    and they issued Russian-related GL 13S (Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024):

    russia_gl13sDownload

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  • September 28, 2026: 3 OFAC Venezuela General Licenses get new versions

    Venezuela-related General License 46E, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products”:

    venezuela_gl46eDownload

    Venezuela-related General License 48D, “Authorizing the Supply of Certain Items and Services to Venezuela”:

    venezuela_gl48dDownload

     Venezuela-related General License 49B, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela”:

    venezuela_gl49bDownload

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  • September 18, 2026: OFAC Update, Part 3: New version of Russia General License 131, plus amended Frequently Asked Questions

    Today, OFAC issues Russia-related GL 131J:

    russia_gl131jDownload

    and updated FAQs 1224 and 1225 accordingly:

    1225. What activities do Russia-related General License 128C and General License 131J authorize related to Lukoil International GmbH (LIG)? 

    OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128C and GL 131J. The GLs are similar but have different expiration dates and terms as each serves a different purpose.

    • To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. OFAC subsequently issued GL 128C to extend the existing authorization until October 29, 2026.
    • To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B, 131C, 131D, GL 131E, GL 131F, GL 131G, GL 131H, GL 131I, and GL 131J, to extend the existing authorization until October 22, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

    GL 128C and GL 131J expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128C and GL 131J. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128C and GL 131J authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.

    Both GL 128C and GL 131J also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

    Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128C and GL 131J. Similarly, non-U.S. persons may rely upon GL 128C and GL 131J regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128C and GL 131J, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

    Date Updated: September 18, 2026

    Updated on Sep 18, 2026

    Russian Harmful Foreign Activities Sanctions

    1224. What negotiations does Russia-related General License 131J authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets? 

    On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131J, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131Jexpires on October 22, 2026.

    GL 131J does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131J must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war.

    As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.

    OFAC may revoke GL 131J at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.

    Date Updated: September 18, 2026

    Updated on Sep 18, 2026

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  • 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 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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