Mr. Sanctions

Category: Frequently Asked Questions (FAQs)

  • March 19, 2026: Another day, another version of OFAC Venezuela General License 5 (and the related FAQ)

    This one is General License 5V:

    venezuela_gl5vDownload

    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    General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license.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

    —

    , , ,

  • March 18, 2026: OFAC Venezuela General License 52, and 2 new Frequently Asked Questions, opens the PdVSA spigot further

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

    venezuela_gl52Download

    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 §§ 591.309, 591.310, and 591.407.

    Date Released

    March 18, 2026

    —

    , , ,

  • March 13, 2026: 3 Venezuela GLs, 2 FAQs updated

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

    venezuela_gl46bDownload

    48A:

    venezuela_gl48aDownload

    and 49A:

    venezuela_gl49aDownload

    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

    —

    , , ,

  • March 5. 2026: OFAC issues new Russia-related General License, amends Veneuzuala FAQ

    On Thursday, OFAC issued Russia-releated General License 133 (Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 5, 2026 to India):

    russia_gl133Download

    and amended Venezuela-related Frequently-Asked Question 1238:

    1238. Would OFAC approve the resale of Venezuelan origin oil to Cuba?

    Answer

    In accordance with the United States’ support and solidarity for the Cuban people, OFAC would implement a favorable licensing policy toward specific license applications seeking authorization for the resale of Venezuelan-origin oil for use in Cuba. To qualify for this favorable licensing policy, the requested transactions would need to be consistent with the terms and conditions of Venezuela General License (GL) 46A, though applicants need not necessarily have an established U.S. entity and the limitations in GL 46A with respect to Cuba would not apply. This favorable licensing policy is directed towards transactions that support the Cuban people, including the Cuban private sector (e.g., exports for commercial and humanitarian use in Cuba). Consistent with applicable U.S. law and policy, transactions involving, or for the benefit, of any persons or entities associated with the Cuban military, intelligence services, or other government institutions, including entities listed on the U.S. State Department’s Cuba Restricted List, see 31 C.F.R. 515.209, as well as any Cuban-owned financial institutions, would not be covered by this favorable licensing policy (collectively, the “excluded parties”).

    Parties seeking a license under this policy must implement measures to ensure that no subsequent transactions related to the Venezuelan-origin oil involve or benefit, either directly or indirectly, the excluded parties. These measures should include provisions in sale or resale agreements prohibiting any direct or indirect participation by the excluded parties in any present or future transaction related to the Venezuelan-origin oil, as well as requirements that any present or future financial transactions involving the sale or resale of the Venezuelan-origin oil are routed through a financial institution based in the United States, or otherwise do not involve transactions routed through financial institutions associated with, or controlled by, the excluded parties.

    As a reminder, the U.S. Department of Commerce primarily regulates the export or reexport of U.S.-origin oil to Cuba, as well as all other items subject to the Export Administration Regulations (EAR, 15 C.F.R. parts 730-774). Treasury’s Cuban Assets Control Regulations generally authorize U.S. persons to engage in transactions ordinarily incident to the export of oil from the United States to Cuba, or the reexport of U.S.-origin oil from a third country to Cuba, where that export or reexport has been authorized by the Commerce Department. See 31 C.F.R. 515.533(a). This authorization applies to transactions covered by applicable Commerce Department license exceptions, including License Exception Support for the Cuban People (SCP), 15 CFR § 740.21, which authorizes exports and reexports of gas and other petroleum products to improve living conditions and support independent economic activity. In other words, U.S.-origin oil exports, as well as other gas and petroleum products covered by License Exception SCP, do not require separate OFAC authorizations. Exporters and reexporters are responsible for reviewing current Commerce Department guidance, see here, and ensuring that any transaction undertaken pursuant to License Exception SCP or any other license exception meet all applicable terms and conditions.

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

    Date Updated: March 05, 2026

    Date Released

    February 25, 2026

    —

    , , , ,

  • March 4, 2026: OFAC issues 6 new Venezuela FAQs

    FAQs 1239-1244:

    1244. How will OFAC assess specific license applications to perform any contingent contracts that are executed pursuant to Venezuela General License (GL) 49? 

    Specific license applications to perform any contingent contracts executed pursuant to GL 49 will be assessed on a case-by-case basis consistent with U.S. foreign policy and national security priorities. Recent Venezuela-related general licenses issued by OFAC have included various limitations in line with these U.S. priorities, which we encourage parties to consider during contract negotiations. Such restrictions have included prohibitions on transactions involving persons located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, the People’s Republic of China, or any entity owned or controlled by or in a joint venture with such persons; required that transactions are conducted on commercially reasonable terms; required that contracts specify U.S. jurisdiction for dispute resolution; and required that payment of royalties or other funds owed to blocked persons—excluding local taxes, permits, and fees—are made into the Foreign Government Deposit Funds or other accounts designated by Treasury.

    Released on Mar 04, 2026

    Venezuela Sanctions

    1243. What authorizations exist to develop oil or gas projects in Venezuela for companies that are not listed in Venezuela General License (GL) 50A (Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities)? 

    Entities not identified in the Annex to GL 50A can rely on other authorizations to support the development of oil or gas projects in Venezuela. For example, such companies can enter into contingent contracts for new investments in the Venezuela oil or gas sectors pursuant to GL 49 and submit a specific license application to OFAC to request additional authorization to perform any contingent contracts executed.

    Additionally, GL 48 authorizes, subject to certain restrictions, the provision of goods, technology, software, or services from the United States or by a U.S. person for the exploration, development, or production of oil or gas in Venezuela. Transactions authorized under GL 48 include activities in support of: (1) existing oil or gas operations in Venezuela, or (2) exploration or due diligence activities necessary to inform future joint ventures or other oil or gas developments, such as the importation of software to assist in conducting site surveys, data processing or modeling, or seismic or geologic studies, for example. For more information on what transactions are authorized and excluded by GL 48, see FAQ 1241.

    Taken together, GLs 48 and 49 authorize all transactions otherwise prohibited by the Venezuela Sanctions Regulations (VSR) by interested parties to conduct all necessary due diligence activities—including the importation of goods, services, or technologies consistent with U.S. export control law—to inform the negotiation of and entry into contingent contracts for new investment in the oil or gas sector of Venezuela.

    Alternatively, U.S. persons could also enter into contracts with entities identified in the Annex of GL 50A to support authorized activities in the Venezuelan oil or gas sectors. For more information on what transactions GL 50A authorizes, see FAQ 1242. 

    Released on Mar 04, 2026

    Venezuela Sanctions

    1242. What does Venezuela General License (GL) 50A authorize? 

    GL 50A authorizes, subject to its conditions and exclusions, transactions prohibited by the Venezuela Sanctions Regulations (VSR) that are related to oil or gas sector operations in Venezuela of the entities listed in the Annex to GL 50A and their subsidiaries. Transactions authorized by Venezuela GL 50A include:

    • the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of oil or gas from Venezuela, as well as the refining of such oil or gas;
    • the provision or receipt of goods, services, software, or technology related to oil or gas sector operations in Venezuela;
    • new investment in oil or gas sector operations in Venezuela, including expanding existing operations in Venezuela, engaging in new oil or gas exploration, production, or development activities in Venezuela, and forming new joint ventures or other entities in Venezuela related to the foregoing activities;
    • engaging in prefatory steps for any of the foregoing activities, such as conducting commercial, legal, technical, safety, and environmental due diligence and assessments; and
    • the processing of payments related to any of the aforementioned activities.

    Additionally, U.S. persons may enter into contracts with entities identified in the Annex of GL 50A that are ordinarily incident and necessary to transactions authorized by GL 50A.

    Released on Mar 04, 2026

    Venezuela Sanctions

    1241. What does Venezuela General License (GL) 48 (Authorizing the Supply of Certain Items and Services to Venezuela) authorize? 

    GL 48 authorizes the provision of goods, technology, software, or services from the United States or by a U.S. person for the exploration, development, or production of oil or gas in Venezuela.

    Examples of authorized transactions under GL 48 include the provision of:

    • insurance services for oil and gas operations;
    • maintenance, refurbishment, or repair of items used for oil or gas exploration, development, or production activities;
    • spare or replacement parts required to maintain oil or gas production activities;
    • exploration and subsurface interpretation software;
    • well stimulation products such as fracturing fluids; or
    • the processing of payments from the Government of Venezuela (GOV) or other authorized blocked persons for the underlying transactions. However, any monetary payment to the GOV or Petróleos de Venezuela, S.A. (PdVSA) or its majority-owned subsidiaries (other than payments for local taxes, permits, or fees) must be deposited into the Foreign Government Deposit Funds established pursuant to Executive Order (E.O.) 14373, or another Treasury-instructed account. See FAQ 1237 for information on the payment of local taxes, permits, and fees to the GOV.

    GL 48 does not authorize the formation of new joint ventures or other corporate entities in Venezuela to explore or produce oil or gas, nor does it authorize any transaction related to a joint venture involving the Russian Federation or the People’s Republic of China, among other conditions. Please note that certain export activities authorized by GL 48 may require additional authorization from the Commerce Department’s Bureau of Industry and Security.

    Released on Mar 04, 2026

    Venezuela Sanctions

    1240. For purposes of Venezuela General License (GL) 47 (Authorizing the Sale of U.S.-Origin Diluents to Venezuela), how does OFAC define diluent? 

    For the purposes of GL 47, diluent means a light hydrocarbon liquid, such as natural gas condensate, naphtha, or light crude oil, that is added to heavy crude oil or bitumen to reduce its viscosity and density in order to transport, export, store, or process more easily.

    Released on Mar 04, 2026

    Venezuela Sanctions

    1239. Where can I find the account information to make authorized payments to the Foreign Government Deposit Funds, as specified in Executive Order 14373? 

    To obtain payment account information for payments to the Foreign Government Deposit Funds, as specified in Executive Order (E.O.) 14373, “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People,” and referenced in certain Venezuela General Licenses, please contact DepositorInquiries@state.gov. Please be prepared to provide all relevant transaction details, including the following, as appropriate:

    • Full legal names and addresses of corporate depositor and all contract parties (provide subsidiary information, as applicable);
    • Detailed description of the underlying contract or obligation, including the purpose and nature of the payment (include information on the type of product and amount purchased and/or sold);
    • Date of sale and copies of the corresponding invoice(s), contract number(s), and any relevant reference identifiers;
    • Total payment amount, currency, and proposed payment date;
    • Identification of the license authorizing the transaction;
    • Copies of any other transaction record(s) to validate the deposit; and
    • Primary point of contact for any follow-up questions, including name, title, telephone number, and email address.

    Released on Mar 04, 2026

    —

    , ,

  • February 26, 2026: The Russia-related Half of today’s OFAC action

    There’s a new version of General License 131:

    russia_gl131cDownload

    And the related Frequently Asked Questions (FAQs) were updated, too – 1224:

    1224. What negotiations does Russia-related General License 131C 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) 131C, 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 131C expires on April 1, 2026.

    GL 131C 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 131C 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 131C 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: February 26, 2026

    Date Released

    November 19, 2025

    and 1225:

    1225. What activities do Russia-related General License 128B and General License 131Cauthorize 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 128B and GL 131C. 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. This GLexpires on April 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 and 131C to extend the existing authorization until April 1, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

    GL 128B and GL 131C 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 128B and GL 131C. 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 128B and GL 131C 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 128B and GL 131C 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 128B and GL 131C. Similarly, non-U.S. persons may rely upon GL 128B and GL 131C 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 128Band GL 131C, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

    Date Updated: February 26, 2026

    Date Released

    December 4, 2025

    —

    , , ,

  • February 25, 2026: OFSI amends a Russia GL and an FAQ

    Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence INT/2025/8031092 amended and 1 FAQ amended

    On 25 February 2026, the General Licence INT/2025/8031092 was amended, the expiry date was extended to 25 August 2026.

    Any persons intending to use General Licence INT/2025/8031092 should consult the copy of the Licence for full details of the permissions and usage requirements.

    FAQ 174 was also amended to reflect the amendment of the general licence.

    The General License:

    General_Licence_-_Continuation_of_Business_Lukoil_International–Feb_2026Download

    The FAQ:

    174.Can business operations with Lukoil International GmbH continue as normal with regard to UK financial sanctions?

    On 15 October 2025, the UK designated PJSC Oil Company Lukoil (“Lukoil”) under the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”). Lukoil is consequently subject to financial sanctions, as are entities owned or controlled by Lukoil.

    OFSI notes the ongoing negotiations on the sale of PJSC Lukoil’s international assets.

    In that context, on 27 November 2025 OFSI issued General Licence INT/2025/8031092. This GL permits the continuation of business with respect to Lukoil International GmbH (“Lukoil International”) which is a subsidiary of PJSC Lukoil and subsidiaries of Lukoil International.

    Users of General Licence INT/2025/8031092 should carefully consider all relevant conditions, in particular those relating to payments made to Lukoil International and/ or Lukoil International subsidiaries.

    In line with OFSI licensing practice the expiry date of General Licence INT/2025/8031092 is set out in the amended licence document. Any renewal of General Licence INT/2025/8031092 would be considered in the context of the ongoing negotiations on the sale of PJSC Lukoil’s international assets.

    HM Treasury may vary, revoke or suspend General Licence INT/2025/8031092 at any time.

    Amended on: 25 Feb 2026

    —

    , , ,

  • February 26, 2025: OFAC publishes a new Venezuela FAQ

    The new magic number? 1238:

    VENEZUELA SANCTIONS

    1238. Would OFAC approve the resale of Venezuelan origin oil to Cuba?

    In accordance with the United States’ support and solidarity for the Cuban people, OFAC would implement a favorable licensing policy toward specific license applications seeking authorization for the resale of Venezuelan origin oil for use in Cuba. To qualify for this favorable licensing policy, the requested transactions would need to be consistent with the terms and conditions of Venezuela General License (GL) 46A, though applicants need not necessarily have an established U.S. entity and the limitations in GL 46A with respect to Cuba would not apply. This favorable licensing policy is directed towards transactions that support the Cuban people, including the Cuban private sector (e.g., exports for commercial and humanitarian use in Cuba). Consistent with applicable U.S. law and policy, transactions involving, or for the benefit, of any persons or entities associated with the Cuban military, intelligence services, or other government institutions, including entities listed on the U.S. State Department’s Cuba Restricted List, see 31 C.F.R. § 515.209, would not be covered by this favorable licensing policy.

    As a reminder, the U.S. Department of Commerce primarily regulates the export or reexport of U.S.-origin oil to Cuba, as well as all other items subject to the Export Administration Regulations (EAR, 15 C.F.R. parts 730-774). Treasury’s Cuban Assets Control Regulations generally authorize U.S. persons to engage in transactions ordinarily incident to the export of oil from the United States to Cuba, or the reexport of U.S.-origin oil from a third country to Cuba, where that export or reexport has been authorized by the Commerce Department. See 31 C.F.R. § 515.533(a). This authorization applies to transactions covered by applicable Commerce Department license exceptions, including License Exception Support for the Cuban People (SCP), 15 C.F.R. § 740.21, which authorizes exports and reexports of gas and other petroleum products to improve living conditions and support independent economic activity. In other words, U.S.-origin oil exports, as well as other gas and petroleum products covered by License Exception SCP, do not require separate OFAC authorizations. Exporters and reexporters are responsible for reviewing current Commerce Department guidance, see here, and ensuring that any transaction undertaken pursuant to License Exception SCP or any other license exception meet all applicable terms and conditions.

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

    Date Released

    February 25, 2026

    —

    , ,

  • February 18, 2026: Two new Venezuela-related FAQs

    Yesterday, OFAC published Venezuela-related Frequently Asked Question (FAQ) 1236:

    1236. How does Venezuela General License (GL) 30B differ from Venezuela GL 30A?

    On February 10, 2026 OFAC issued Venezuela GL 30B, “Authorizing Certain Transactions Necessary to Port and Airport Operations,” which removes the prohibition in GL 30A regarding transactions or activities related to the exportation or reexportation of diluents to Venezuela.  Transactions authorized by GL 30B continue to include payments that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela, including transactions involving the Instituto Nacional de los Espacios Acuaticos (INEA) or its majority-owned subsidiaries.  GL 30B authorizes the payment of port fees and customs duties—including for activities authorized under Venezuela GLs 46A, 47, and 48.

    Date Released

    February 18, 2026

    and 1237:

    1237. Do Venezuela General Licenses (GLs) 46Aand 48 allow for the payments of certain local taxes, permits, and fees in support of authorized transactions involving Venezuela’s oil or gas sectors?

    Yes.  Consistent with other authorizations issued by OFAC pursuant to the Venezuela Sanctions Regulations (VSR), GLs 46A and 48authorize routine payments of local taxes, permits, and fees to the Government of Venezuela (GOV) or its instrumentalities.

    However, other payments, including royalties, fixed per-barrel production levies, or federal taxes to blocked persons, such as the GOV or Petróleos de Venezuela, S.A. (PdVSA), must be made into the Foreign Government Deposit Funds, as specified in Executive Order (E.O.) 14373, or any other account as instructed by the U.S. Department of the Treasury.

    Date Released

    February 18, 2026

    —

    , ,

  • February 6, 2026: Friday FAQs for OFAC Venezuela program

    Announced late Friday:

    1235. Does Venezuela General License (GL) 46 authorize downstream trading activities in Venezuelan-origin oil? 

    Yes. Once a transaction with the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (PdVSA), or its majority-owned subsidiaries (PdVSA Entities) has been completed pursuant to GL 46, and the interest—including any future or contingent interest—of a blocked entity is fully extinguished, then the oil can be freely sold, resold, and traded by any downstream purchaser, including entities that are not established U.S. entities, as defined in GL 46.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1234. How does a financial institution verify a transaction is compliant with Venezuela General License (GL) 46? 

    In connection with its normal due diligence, a financial institution may rely on the statements of its customer that the transaction is consistent with the terms of GL 46, unless it knows or has reason to know otherwise.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1233. Are all entities engaged in a transaction authorized by Venezuela General License (GL) 46 required to have contracts with the dispute resolution requirement included in paragraph (a)(1)? 

    No. The dispute resolution requirement in paragraph (a)(1) of GL 46 applies only to contracts governing transactions undertaken by an established U.S. entity when the contract is with the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (PdVSA Entities).

    This requirement does not apply to indirect parties or indirect counterparties involved in transactions authorized by GL 46, such as downstream transactions involving the provision of shipping, insurance, or other services to an entity engaged in a transaction involving PdVSA. For example, this provision would not apply to a contract between an insurance provider and an established U.S. entity engaged in a transaction with PdVSA to purchase Venezuelan-origin oil (though it would apply to the contract between the U.S. entity and PdVSA).

    Released on Feb 06, 2026

    Venezuela Sanctions

    1232. What does OFAC consider “commercially reasonable terms,” as described in Venezuela General License (GL) 46? 

    “Commercially reasonable terms” means terms that are consistent with prevailing market and industry standards for like or similar products produced by a company of similar size and scope, while taking into account characteristics such as quality, quantity, pricing, performance, and safety, among others. Commercially reasonable terms include terms related to, among other things, the governance, economics, operations, and legal/compliance requirements of a contract negotiated at arm’s length between two or more parties.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1231. What entities or jurisdictions are excluded from transactions authorized under Venezuela General License (GL) 46? 

    GL 46 excludes the involvement of persons located in or organized under the laws of the Russia Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, and the Republic of Cuba—as well as any entity owned or controlled, directly or indirectly (including by or in a joint venture with) any of the foregoing.

    In addition, GL 46 does not authorize transactions with any Venezuelan or U.S. entity that is owned or controlled by, or in a joint venture with, a person located in or organized under the laws of the People’s Republic of China. However, GL 46 does not restrict the resale of Venezuelan-origin oil to China by an established U.S. entity.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1230. Can an entity that is not an “established U.S. entity” be involved in transactions authorized by Venezuela General License (GL) 46? 

    Yes. Non-U.S. persons may engage in transactions or provide services that are ordinarily incident and necessary to the established U.S. entity’s transactions authorized by GL 46. Such activities or ancillary services could include: providing transportation and logistics services to an established U.S. entity for the export of Venezuelan-origin oil; providing marine insurance to vessels chartered by established U.S. entities to transport Venezuelan-origin oil; the financing of related cargoes or receivables; leasing storage facilities for Venezuelan-origin oil purchased by an established U.S. entity; or contracting with established U.S. entities for repair or maintenance services of infrastructure necessary to effectuate the export of oil from Venezuela, among others.

    Please see FAQ 1235 for additional information regarding authorized downstream trading activities.

    Please see FAQ 1231 for certain individuals and jurisdictions excluded from the scope of GL 46.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1229. Venezuela General License (GL) 46 authorizes certain activity by an “established U.S. entity.” What is an “established U.S. entity” for purposes of GL 46? 

    For purposes of GL 46, the term “established U.S. entity” means any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.

    GL 46 is designed to help ensure that the oil exported from Venezuela will be through legitimate and authorized channels, consistent with U.S. law and President Trump’s efforts to restore prosperity, safety, and security to the United States and Venezuela. Established U.S. companies should be familiar with complying with U.S. laws and regulations, including U.S. sanctions regulations, which will help ensure their ability to market Venezuelan oil in the global marketplace for the benefit of the United States, Venezuela, and our allies.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1228. Does Venezuela General License (GL) 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil,” authorize exploration activity or negotiations for new investment activities? 

    No. GL 46 authorizes the purchase, exportation, and sale of Venezuelan-origin oil that has already been extracted, including the refining of such oil. It does not authorize other exploration or production activities, such as conducting geological surveys, drilling wells, or extracting oil from fields in Venezuela, nor does it authorize activities related to investment in the Venezuelan oil sector, such as negotiations with Petróleos de Venezuela, S.A. (PdVSA) to enter into a contract to develop or operate oil fields, blocks, or other concessions. For more information on what transactions are authorized by GL 46, see FAQ 1227.

    Released on Feb 06, 2026

    Venezuela Sanctions

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

    GL 46 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 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 46 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 46, see FAQ 1230.

    Released on Feb 06, 2026

    Venezuela Sanctions

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

    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 46.

    Released on Feb 06, 2026

    —

    , ,