Mr. Sanctions

Category: Regulatory

  • April 14, 2026: OFAC Update 1, Part 2: New and updated General Licenses, and an updated Frequently Asked Question

    From OFAC’s Recent Actions Notice:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Counter Terrorism General License 35, “Authorizing the Wind Down of Transactions Involving Entities Blocked on April 14, 2026.”

    ct_gl35Download

    OFAC is also issuing Russia-related General License 128C, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia,” 

    russia_gl128cDownload

    Russia-related General License 130A, “Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria,

    russia_gl130aDownload

    and is amending one Russia-related Frequently Asked Question (FAQ 1225).

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

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

    Date Updated: April 14, 2026

    Date Released

    December 4, 2025

    —

    , , , , ,

  • April 13, 2026: Not so fast! OFSI extends deadline for ownership and control input

    Office of Financial Sanctions Implementation HM Treasury

    Call for evidence on ownership and control in financial sanctions regulations

    OFSI has extended the deadline for its call for evidence on how UK financial sanctions regulations on ownership and control are applied in practice. The call for evidence will now close at 11:59pm on Monday 20th April 2026.

    We have extended the deadline to allow firms and other stakeholders more time to prepare and submit evidence, including practical examples from real cases. 

    The Call for Evidence seeks industry views on how the ownership and control test is applied in practice, including where firms face challenges. The test is designed to stop designated persons from sidestepping UK sanctions by hiding behind complex company structures, trusts or proxies. However, assessing the ability of a designated person to control an entity — even if they are not actively doing so — can be difficult in practice and may create additional costs and legal risk.

    We are particularly interested in evidence and examples on:

    • How often ‘hypothetical control’ is present in real financial sanctions cases; 
    • The impact it has on compliance costs, legal risk and business decisions (including derisking); 
    • Whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations.  

    Read the full call for evidence and how to respond here.   

    Read more about the background and scope of the exercise in our blog here.

    —

    , , ,

  • April 8, 2026: OFAC updates Russian General License 13 & associated Frequently Asked Questions

    Today, OFAC issued Russia-related General License 13Q:

    russia_gl13qDownload

    and updated two FAQs:

    1118. As of December 2022, the Government of the Russian Federation may require a so-called “exit tax” payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called “exit tax”? Does Russia-related General License (GL) 13Q authorize transactions that involve the payment of this exit tax? 

    Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibits the following activities by U.S. persons: any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (collectively, “Directive 4 entities”). As noted in FAQ 1002, this includes both direct and indirect transactions.

    OFAC issued the Russia-related Sovereign Transactions Directive with the explicit aim of preventing the Government of the Russian Federation from leveraging these institutions and their holdings of international reserves in ways that would undermine the impact of U.S. sanctions. Information currently available to OFAC suggests so-called “exit taxes” imposed by the Government of the Russian Federation involve payments to Directive 4 entities. Consequently, U.S. persons whose divestment from the Russian Federation will involve the payment of such an exit tax require a specific license from OFAC prior to the payment of such tax, unless otherwise authorized by OFAC.

    GL 13Q authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications involving Directive 4 entities that would otherwise be prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. Payment of exit taxes is not considered ordinarily incident and necessary to day-to-day operations in the Russian Federation and, thus, is not authorized under GL 13Q.

    Therefore, U.S. persons whose divestment of assets in the Russian Federation will involve a payment of such an “exit tax” should seek a specific license from OFAC. Such persons may submit a request for a specific license with OFAC’s Licensing Division online at https://ofac.treasury.gov/ofac-license-application-page. License applications related to these payments should include information regarding the amount of the exit tax, the amount of ongoing taxes that would otherwise be paid to the Government of the Russian Federation should divestment not occur, the impact of a failure to pay the tax on the employees of the exiting company, the specific economic activity in Russia of the exiting company, and the impact on the Russian Federation of the divestment. OFAC will expedite its review of such requests, which will be evaluated on a case-by-case basis.

    While OFAC is aware that the Commission established by the Russian Federation to review such divestments may include individuals from entities subject to the Russia-related Sovereign Transactions Directive or individuals listed on the Specially Designated Nationals and Blocked Persons List, U.S. persons do not need to seek authorization from OFAC for their Russian buyers to submit an application to the Commission regarding a divestment transaction.

    Date Updated: April 08, 2026

    Updated on Apr 08, 2026

    Russian Harmful Foreign Activities Sanctions

    999. What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)? 

    OFAC issued Russia-related General License (GL) 132 to authorize transactions involving the Paks II civil nuclear power plant project in Hungary, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.

    OFAC issued Russia-related General License (GL) 115C to authorize civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.

    OFAC issued GL 13Q to authorize U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. For further information on the types of transactions authorized by GL 13Q, see FAQ 1118.

    OFAC also issued GL 14, authorizing certain transactions involving any Directive 4 entity where the Directive 4 entity’s sole function in the transaction is to act as an operator of a clearing and settlement system. GL 14 does not authorize any transfer of assets to or from any Directive 4 entity, or any transaction where a Directive 4 entity is either a counterparty or beneficiary to the transaction. In addition, GL 14 does not authorize any debit to an account on the books of a U.S. financial institution of any Directive 4 entity. See FAQ 1003.

    Note that GL 13Q, GL 14, GL 115C, and GL 132 continue to authorize against the Russia-related Sovereign Transactions Directive.

    Date Updated: April 08, 2026

    Updated on Apr 08, 2026

    —

    , , ,

  • April 8, 2026: ¿Habla usted OFAC?

    From today’s OFAC Recent Actions page:

    OFAC has published Spanish translations of Venezuela General License 46B, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;” Venezuela General License 47, “Authorizing the Sale of U.S.-Origin Diluents to Venezuela;” Venezuela General License 48A, “Authorizing the Supply of Certain Items and Services to Venezuela;” Venezuela General License 49A, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela;” and Venezuela General License 50A, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities.” The translations of these General Licenses are available at this link, and the translations of 19 associated Frequently Asked Questions are available at this link. Note: These Spanish translations are for informational purposes only.

    —

    , , , ,

  • April 1, 2026: OFAC issues more aggressive guidance, a General License and FAQs about the Shadow Fleet

    U.S. DEPARTMENT OF THE TREASURY

    Office of Foreign Assets Control

    April 1, 2026

    Publication of Sanctions Advisory: Guidance on Identifying “Non-Standard Maritime Silhouettes” and Active Camouflage within the Shadow Fleet

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the U.S. Department of State and the U.S. Coast Guard, is issuing this advisory to alert the maritime industry to “Visual Signal Obfuscation” (VSO) tactics currently employed by the Shadow Fleet to circumvent the G7+ Price Cap and avoid detection in high-traffic corridors.

    As outlined in Executive Order 14501, “Addressing Extra-Territorial Maritime Deception,” U.S. persons are advised that the use of “Trompe-l’œil” hull painting, inflatable superstructure extensions, and “active-chameleon” heat-shielding technology constitutes a significant evasion risk.

    Regulatory Concerns: The “Iceberg” and “Megayacht” Protocols

    OFAC has identified a trend where sanctioned crude oil tankers are undergoing structural modifications to appear as non-sanctioned vessel types when viewed from satellite or aerial surveillance. Recent findings include:

    • Pseudo-Leisure Conversions: Tankers utilizing magnetic “hull-wraps” to mimic the visual signature of luxury pleasure craft or research vessels.
    • Active Camouflage (AC): The application of light-refractive coatings that cause the vessel to blend into sea-state patterns or, in Arctic routes, mimic the geometric profile of large icebergs.
    • Bio-Mimicry Signatures: The deployment of acoustic decoys that broadcast the frequency of migratory whale pods to confuse sonar-based tracking systems.

    Compliance Expectations

    Marine insurers, port authorities, and bunkering services are expected to conduct “Optical Due Diligence.” If a vessel’s length-to-beam ratio appears to “shimmer” or fluctuate during daylight hours, it must be flagged as a “Potential Visual Evasion Event” (PVEE).

    And a new General License:

    GL 1-APRDownload

    And a new Frequently Asked Question:

    Frequently Asked Question (FAQ) 1401

    Q: My satellite imagery shows a tanker that looks like a giant floating rubber duck. Is this a sanctioned vessel?

    A: Possibly. Under the “Strict Liability” standard, the internal cargo (crude oil) determines the sanctions status, regardless of whether the external hull is yellow, buoyant, or has a beak. OFAC recommends that you do not “squeeze” the duck until you have verified the Ultimate Beneficial Owner (UBO) via the hotline at 1-800-APR-FOOL.

    oh, and one more thing, in case it wasn’t clear…

    Thanks a bunch, Gemini! April Fool!

    —

    , , ,

  • Burning Question: The march of time (and minimizing sanctions evasion)

    so, I asked Gemini to build the story of sanctions evasion-related advisory and guidance documents. Its response:

    The latest advisory from March 31, 2026, titled “Guidance on Sham Transactions and Sanctions Evasion,” signals a new frontier in the U.S. government’s efforts to stop illicit actors from hiding their wealth. By reviewing this document and the history of OFAC’s guidance, we can see a clear evolution: sanctions have moved from simple “do not trade with this person” lists to complex “detective manuals” that require companies to spot sophisticated lies.

    Part 1: Summary of Today’s Advisory (March 31, 2026)

    Verified Document: Guidance on Sham Transactions and Sanctions Evasion.

    The core message of this document is that a “paper trail” is no longer enough to prove a transaction is legal. OFAC is warning that blocked individuals—such as sanctioned Russian oligarchs or international drug kingpins—are using “Sham Transactions” to pretend they no longer own their luxury assets (like private jets, yachts, or companies).

    Key “Red Flags” for Sham Transactions:

    • Family Transfers: A sanctioned person “sells” or transfers an asset to a spouse, child, or close associate shortly before or after being sanctioned.
    • Below-Market Deals: Selling a multi-million dollar asset for a tiny fraction of its value, or on terms that don’t make business sense.
    • Invisible Control: The sanctioned person “sells” their private jet but continues to use it for personal travel, meaning they still effectively own it.
    • Unnecessary Complexity: Using layers of shell companies in “tax haven” countries to hide who really benefits from the property.

    Part 2: The Evolution of Sanctions Evasion Guidance

    Over the last decade, OFAC’s guidance has evolved through four distinct “generations.”

    1. The “Who” Era (Foundational / Pre-2019)

    In this era, compliance was relatively simple: don’t do business with anyone on the SDN List (Specially Designated Nationals).

    • The Big Rule (2014): OFAC clarified the “50 Percent Rule,” stating that if a sanctioned person owns 50% or more of any company, that company is also automatically sanctioned—even if its name isn’t on a list.
    • The Evasion: People began splitting ownership into 49% chunks to stay “under the radar.”

    2. The “How” Era (2019: The Framework)

    OFAC realized that companies needed a “playbook” to avoid making mistakes.

    • Key Document: A Framework for OFAC Compliance Commitments (May 2019).
    • Evolution: This established the “5 Pillars” of a good compliance program: management support, risk assessment, internal controls, testing, and training. It told companies: “We won’t just look at who you trade with; we will look at how hard you tried to follow the rules”.

    3. The “Behavioral” Era (2020: Global Maritime Advisory)

    Sanctions evasion moved to the high seas, where bad actors began using “Deceptive Shipping Practices” (DSPs).

    • Key Document: 2020 Global Maritime Advisory.
    • Evolution: Guidance shifted from “Lists” to “Patterns”. Companies were told to watch for ships turning off their GPS (AIS), “spoofing” their location, or transferring cargo between ships in the middle of the ocean (STS transfers) to hide the cargo’s origin.

    4. The “Detective” Era (2023–2026: Shadow Fleets and Sham Deals)

    The current era is defined by the war in Ukraine and the “Russian Oil Price Cap”.

    • The “Shadow Fleet”: Guidance now focuses on “Ghost Ships”—older, poorly maintained vessels with fake insurance used to bypass oil price limits.
    • “Know Your Cargo” (2023): A landmark “Quint-Seal” note (issued by five agencies) told companies they must now verify the cargo, not just the customer.
    • The Latest Step (Today): The 2026 “Sham Transactions” advisory completes the circle. It warns that even when the person looks clean and the ship looks clean, the legal paperwork might be a lie.

    Summary for Non-Experts: How the “Rules of the Game” Changed

    Old Way (2016)New Way (2026)
    “Check the List”: If the name isn’t on the SDN list, you are probably fine.“Check the Vibe”: Even if the name is clean, you must ask: “Does this deal make sense? Why is this ship’s GPS off?”.
    “Simple Ownership”: Just check if a sanctioned person owns 51% of a business.“Ultimate Control”: Check if they secretly control it through a trust, a shell company, or their spouse.
    “Bank Responsibility”: Mostly banks and financial firms had to worry about this.“Industry Responsibility”: Insurers, ship captains, freight forwarders, and luxury goods dealers are now on the front lines.

    Today, OFAC treats every company as a “mini-detective agency.” If you ignore a red flag—like an oligarch suddenly “giving” his yacht to his wife for $1—the government can hold you responsible for “sham” activity.

    So, what do you think? The inclusion of the Framework Document seems a bit of a curveball (certainly I didn’t expect that to pop up), but it seems to follow a certain logic….

    —

    , , , ,

  • March 31, 2026 Sanctions-palooza: OFAC issues guidance on “sham transactions” and sanctions evasion

    20260331_sham_transactions_advisoryDownload

    While this seems pretty basic, for those of us who have been in financial crime compliance for a while, it’s always good to publish this as a reminder for those new to the field or those caught up in the day-to-day who could use a refresher….

    —

    , , ,

  • March 31, 2026 Sanctions-palooza: Happy 10th Anniversary, OFSI!

    Apparently, it’s the aluminum anniversary… being celebrated with a blog post:

    OFSI’s 10 Year Anniversary – Reflections from Giles Thomson, Director of OFSI

    Giles Thomson, 31 March 2026 – OFSI Blog

    Ten years ago, the Office of Financial Sanctions Implementation (OFSI) was established to ensure that the United Kingdom’s financial sanctions are clearly understood, effectively implemented and robustly enforced. 

    Over the past decade, financial sanctions have become an increasingly important tool in furthering the UK’s foreign policy, national security and economic aims. Financial sanctions now operate across a wider range of sectors, markets and jurisdictions than ever before. Their impact, and the demands placed on those responsible for implementing them, are continuing to grow.  

    Sanctions regimes and designations have expanded, and the scale of our sanctions’ implementation is reflected in recent figures. The OFSI Annual Review 2024-2025 saw £37 billion in assets be reported to OFSI as frozen across all sanction’s regimes. 

    From the outset, our role has been to ensure that financial sanctions work in practice, enabling the private sector to implement them effectively. That means ensuring measures are targeted and impactful, while minimising unintended consequences for legitimate activity and providing clarity for those required to comply with the rules. 

    We have strengthened the UK’s financial sanctions framework in several ways. Our engagement with industry has expanded through FAQs, guidance, threat assessments sector-specific advisories and outreach across a wide range of sectors. 

    Licensing remains a central part of the system, enabling legitimate activity to continue where appropriate while maintaining the integrity of sanctions restrictions. This includes a much-enhanced use of General Licences which has brought greater flexibility and efficiency for both public and private sectors. 

    Operational capability has also developed significantly, within OFSI as well as by working with law enforcement partners. Case prioritisation processes have been strengthened through greater use of data, helping identify risks and potential breaches earlier.  

    Since 2023, OFSI has successfully used its powers under the domestic counter-terrorism sanctions regime to designate and disrupt the activity of individuals and entities who pose risks to our national security.  

    International engagement has expanded, recognising that sanctions operate across borders and require close cooperation and alignment with partners to close loopholes. Legislative changes have strengthened reporting requirements and enforcement powers across the UK framework. 

    Enforcement has evolved as well. OFSI’s approach is increasingly targeted, intelligence-led and proactive, using a range of tools — including guidance, warning letters, public disclosure and civil monetary penalties — to promote compliance and deter breaches. Proportionate enforcement remains essential to maintaining confidence in the sanctions’ regime. 

    All this work supports business growth, deters circumvention, and maintains the credibility of the UK’s sanctions framework. 

    This anniversary is an opportunity for me to recognise the many people who have contributed to the development of the UK’s financial sanctions framework over the past decade. I would therefore like to take this opportunity to recognise the expertise and commitment of colleagues, the many people across government, industry, and international partners, and in particular the OFSI staff past and present, who have helped develop and support OFSI since its establishment. 

    As OFSI enters our second decade, our focus is firmly forward-looking and will be captured in a new three-year strategy to be published in the coming weeks. In April, we will convene with partners from across sectors at the OFSI10 Conference, where we will reflect back on our journey so far and look ahead to the future. 

    Ten years on, much has changed. But our mission remains the same: to ensure that the UK’s financial sanctions continue to be clearly understood, effectively implemented and robustly enforced. 

    —

    ,

  • March 31, 2026 Sanctions-palooza: Canada’s guide to export control announcement

    As part of Canada’s ongoing commitment to keeping the exporting community well-informed, this newsletter will now include periodic information on changes to Canada’s export controls. Information on newly enacted sanctions will continue to be included as announced.  

    This message is to notify exporters that as of 30 days from 31 March, 2026, the January 2026 edition of A Guide to Canada’s Export Control List (the Guide) will enter into force.

    The new version of the Guide will bring into force the commitments Canada has made in the various multilateral export control regimes up to January 1, 2026.

    For more information, please see Export and Import Controls.

    The guide is available in sections as opposed to one big PDF:

    A Guide to Canada’s Export Control List

    A Guide to Canada’s Export Control List identifies the items included on the Export Control List that are controlled for export in accordance with section 3 of the Export and Import Permits Act and for which an export permit is required.

    Date of entry into forceLast day in forceBackgrounderNon-official HTML versionOfficial PDF version
    May 1, 2026 Backgrounder – May 2026A Guide to Canada’s Export Control List – May 2026A Guide to Canada’s Export Control List – May 2026 (pdf)
    July 1, 2025April 30, 2026Backgrounder – May 2025A Guide to Canada’s Export Control List – May 2025A Guide to Canada’s Export Control List – May 2025 (pdf)
    May 2, 2024June 30, 2025Backgrounder – January 2024A Guide to Canada’s Export Control List – January 2024A Guide to Canada’s Export Control List – January 2024 (pdf)
    July 1, 2023May 1, 2024Backgrounder – January 2023A Guide to Canada’s Export Control List – January 2023A Guide to Canada’s Export Control List – January 2023 (pdf)
    December 21, 2022June 30, 2023Backgrounder – December 2021A Guide to Canada’s Export Control List – December 2021 (html)A Guide to Canada’s Export Control List – December 2021 (pdf)  
    July 24, 2021December 20, 2022A Guide to Canada’s Export Control List – December 2020 (html)A Guide to Canada’s Export Control List – December 2020 (pdf)
    May 1, 2020July 23, 2021Backgrounder: December 2018A Guide to Canada’s Export Control List – December 2018 (html)A Guide to Canada’s Export List – December 2018 (pdf)
    May 17, 2019April 30, 2020Backgrounder: December 2016A Guide to Canada’s Export Control List – December 2016 (html)A Guide to Canada’s Export Control List – December 2016 (pdf)
    August 11, 2017May 16, 2019A Guide to Canada’s Export Control List – December 2015 (html)A Guide to Canada’s Export Control List – December 2015 (pdf)

    Date modified: 2026-03-18

    —

    , , ,

  • March 31, 2026 Sanctions-palooza: OFAC publishes new Venezuela Frequently Asked Question

    FAQ 1247 was published today:

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

    Answer

    No, provided that non-U.S. persons comply with certain conditions outlined in GLs 46B, 51A, and 52, as described below. Subject to certain conditions, GLs 46B, 51A, and 52 authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), as well as certain transactions 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, or minerals (including gold). Generally, non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized under GLs 46B, 51A, or 52 — such as transacting with PdVSA or importing Venezuelan-origin oil, petrochemical products, or minerals, 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 51A, the transaction does not involve the processing or refining of Venezuelan-origin 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 PdVSA or Venezuelan-origin oil, petrochemical products, and minerals 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 import Venezuelan-origin oil, petrochemical products, and minerals, including gold, 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 52 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 Released

    March 31, 2026

    —

    , ,