Category: General Licenses

  • Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence INT/2023/2824812 extended

    On 27 March 2026, the General Licence INT/2023/2824812 was extended to 26 March 2028.

    Any persons intending to use General Licence INT/2023/2824812 should consult the copy of the Licence for full details of the permissions and usage requirements.

    The long:

    and short of it:

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  • Today’s update includes:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Belarus General License 14, “Authorizing Transactions Involving Belarussian Bank of Development and Reconstruction Belinvestbank Joint Stock Company and Certain Additional Entities.”

    OFAC has also determined, in consultation with the U.S. Department of State, that circumstances no longer warrant the prohibitions imposed on the Ministry of Finance of the Republic of Belarus and the Development Bank of the Republic of Belarus under Directive 1 pursuant to sections 1(a)(ii), 1(b), and 8 of E.O. 14038. Accordingly, OFAC has rescinded Directive 1 under E.O. 14038.

    Pursuant to the following SDN removals, OFAC has archived Belarus General License 13 as it is no longer applicable.

    Here’s the new GL:

  • Today, OFAC issued Venezuela General License 53 (Official Missions of the Government of Venezuela to the United States):

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  • On Friday, OFAC issued Iran-related General License U (Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026):

    I’m not really sure why we issued this – perhaps to provide greater supply on the world petroleum market given the situation in the Straits of Hormuz, despite the fact we’re at war with Iran? IMHO, it’s a head-scratcher….

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  • Office of Financial Sanctions Implementation HM Treasury

    New OFSI General Licence INT/2026/9247168 issued

    On 19 March 2026, the General Licence INT/2026/9247168 was issued which allows activity in relation to the supply, purchase, transportation or delivery of Kazakh Oil.

    Any persons intending to use General Licence INT/2026/9247168 should consult the copy of the Licence for full details of the permissions and usage requirements.

    Here’s the Publication Notice:

    and the Licence:

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  • This one is General License 5V:

    And Frequently Asked Question 595 got updated, too:

    595. What does Venezuela-related General License 5V 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 5V on March 19, 2026, which further delays the effectiveness of the authorization in GL 5 until May 5, 2026. Between October 24, 2019 and May 5, 2026 (the date the authorization in General License 5V 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: March 19, 2026

    Date Released

    January 20, 2022

  • Today, OFAC issued Venezuela GL 52 (Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.):

    and FAQs 1245:

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

    Answer

    GL 52 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 52 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.

    Notably, GL 52 does not authorize transactions that would otherwise be prohibited by the Venezuelan Sanctions Regulations, 31 CFR Part 591, 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.; or
    • transactions involving any other individuals or entities on the Specially Designated Nationals and Blocked Persons List.

    GL 52 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 Venezuela Sanctions Regulations; or
    • any transaction involving a blocked vessel.

    Date Released

    March 18, 2026

    and 1246:

    1246. Does General License 52 authorize the sale of certain shares of CITGO that are the subject of Crystallex International Corporation v. Bolivarian Republic of Venezuela?

    Answer

    No. A specific license will be required before any sale is executed in the Crystallex case.

    Notwithstanding the existence of any general licenses under the Venezuela Sanctions Regulations (VSR), a specific license from OFAC is required for the entry into a settlement agreement, or for 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 blocked pursuant to the VSR.

    For additional information, see 31 CFR §§ 591.309591.310, and 591.407.

    Date Released

    March 18, 2026

  • New Venezuela General License (GL) versions: 46B:

    48A:

    and 49A:

    And the two updated Frequently Asked Questions (FAQs) – 1226:

    1226. Does “Venezuelan-origin oil” as referenced in Venezuela General License (GL) 46B, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products,” include petroleum products? 

    Answer

    Yes. Consistent with the term “Venezuelan oil” as defined in section 5(a) of Executive Order 14245, “Imposing Tariffs on Countries Importing Venezuelan Oil,” the term “Venezuelan-origin oil” means crude oil or petroleum products extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products.

    As defined by the U.S. Energy Information Administration (EIA), petroleum products include unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas, and miscellaneous products obtained from the processing of crude oil (including lease condensate), natural gas, and other hydrocarbon compounds. In keeping with the EIA’s standard definition, petroleum products do not include natural gas, liquefied natural gas, biofuels, methanol, and other non-petroleum fuels.

    Accordingly, crude oil blends such as Merey 16 or bitumen blends, as well as petroleum products or byproducts, including gasoline, asphalt, flexicoke, and petroleum coke, are considered “Venezuelan-origin oil” for the purposes of GL 46B.

    Additionally, on March 13, 2026, OFAC expanded the scope of GL 46B‘s authorizations to include the purchase of Venezuelan-origin petrochemical products, including fertilizer and certain precursor chemicals identified in the Annex of the GL.

    Updated March 13, 2026

    Date Released

    February 6, 2026

    and 1227:

    1227. What activities does Venezuela General License (GL) 46B authorize?

    Answer

    GL 46B authorizes activities that are ordinarily incident and necessary to the lifting (which refers to the physical loading and removal of oil from a terminal, storage facility, or production site for delivery to a buyer), exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil and petrochemical products by an established U.S. entity, which may include:

    • engaging in commercial, legal, and technical discussions necessary to scope purchases of Venezuelan-origin oil, including with third-party legal, commercial, or due diligence consultants;
    • conducting safety, environmental, and other relevant inspections, including site surveys;
    • arranging logistics, security services, delivery points, and shipping preparation, including obtaining marine insurance and engaging with relevant port or maritime authorities of the Government of Venezuela (GOV) or their personnel;
    • conducting certain downstream activities, including the refining and resale of Venezuelan-origin oil;
    • coordinating payment structures, including payments in the form of swaps of oil, diluents, or refined petroleum products, among others;
    • making required repairs and maintenance to pipeline, storage, or port infrastructure necessary to effectuate the loading of vessels; or
    • the financing of related cargos or receivables.

    Notably, GL 46B 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 Venezuela Sanctions Regulations; or
    • any transaction involving a blocked vessel.

    For information on how an entity that is not an “established U.S. entities” (including non-U.S. entities) can be involved in transactions authorized by GL 46B, see FAQ 1230.

    Updated March 13, 2026

    Date Released

    February 6, 2026

  • 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 5PGL 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.