Mr. Sanctions

Category: Venezuela

  • April 1, 2026: Not a joke – Delcy Rodriguez delisted by OFAC

    Venezuela-related Designation Removal

    Delistings:

    The following deletions have been made to OFAC’s SDN List:

    OFAC Program: VENEZUELA Executive Order 13692 of March 8, 2015, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela,” and/or Executive Order 13884 of August 5, 2019, “Blocking Property of the Government of Venezuela.”

    RODRIGUEZ GOMEZ, Delcy Eloina (**AKA: ** RODRIGUEZ, Delcy), Capital District, Venezuela; **DOB: ** 18 May 1969; **citizen: ** Venezuela; **Gender: ** Female; **Cedula No.: ** 10353667 (Venezuela) (individual)

    RODRIGUEZ, Delcy (**AKA: ** RODRIGUEZ GOMEZ, Delcy Eloina), Capital District, Venezuela; **DOB: ** 18 May 1969; **citizen: ** Venezuela; **Gender: ** Female; **Cedula No.: ** 10353667 (Venezuela) (individual)

    —

    , ,

  • 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

    —

    , ,

  • March 27, 2026: A Miner Set of OFAC GLs for Venezuela

    Earlier this evening, OFAC issued a new version of Venezuela General License (GL) 51 (Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold):

    venezuela_gl51aDownload

    and new GLs 54 (Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela):

    venezuela_gl54Download

    and 55 (Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Minerals Sector):

    venezuela_gl55Download

    —

    , ,

  • March 23, 2026: OFAC issues new Venezuela-related General License

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

    venezuela_gl53Download

    —

    , ,

  • 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 6, 2026: OFAC issues Venezuela Gold General License

    On Friday, OFAC issued Venezuela-related General License 51 (Authorizing Certain Activities Involving Venezuelan-Origin Gold):

    venezuela_gl51Download

    —

    , ,

  • 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 5, 2026: The Designation Half of Thursday’s OFAC update

    Venezuela-related Designations Removals; Issuance of Amended Russia-related General License

    Delistings:

    The following deletions have been made to OFAC’s SDN List:

    OFAC Program: [VENEZUELA-EO13850] Executive Order 13850

    ARCTIC VOYAGER INCORPORATED (a.k.a. ARCTIC VOYAGER INC), Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands; Organization Established Date 08 Nov 2024; Identification NumberIMO 0109600; Business Registration Number 128742 (Marshall Islands).

    ARCTIC VOYAGER INC (a.k.a. ARCTIC VOYAGER INCORPORATED), Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands; Organization Established Date 08 Nov 2024; Identification NumberIMO 0109600; Business Registration Number 128742 (Marshall Islands).

    KIARA M (3E2278) Crude Oil Tanker Panama flag; Vessel Year of Build 2004; Vessel Registration Identification IMO 9285823; MMSI 352002348 (vessel) (Linked To: ARCTIC VOYAGER INCORPORATED).

    Amendments:

    Unrelated Administrative List Updates:

    OFAC Program: [DPRK2] Executive Order 13687

    KIM, Yong Bok

    • AKA: * Korean: 김영복
      • “KIM, Yongbok”
    • Korea, North
    • DOB 27 Jul 1957
    • nationality Korea, North
    • Gender Male
    • Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210
    • Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214
    • Passport 654420047 (Korea, North)
    • Deputy Chief of the Korean People’s Army General Staff
    • Party Type: individual

    Supplemental Information: None available.

    List of Changes:

    • Field Name: alt. nationality
      • Deleted: Korea, North
    • Field Name: Title
      • Changed: President of Pyongyang University of Automation to: Deputy Chief of the Korean People’s Army General Staff

    OFAC Program: [RUSSIA-EO14024] Executive Order 14024

    SIBREGIONGAZ, AO

    • AKA: * SIBREGIONGAZ ZAO (Cyrillic: ЗАО СИБРЕГИОНГАЗ)
      • ZAKRYTOE AKTSIONERNOE OBSHCHESTVO SIBREGIONGAZ (Cyrillic: ЗАКРЫТОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО СИБРЕГИОНГАЗ)
    • d. 82 ofis 104/ 4, Prospekt Krasny, Novosibirsk, Novosibirsk Region 630091, Russia
    • Secondary sanctions risk: See Section 11 of Executive Order 14024.
    • Organization Established Date 24 Jul 2003
    • Tax ID No. 5406258514 (Russia)
    • Registration Number 1035402498999 (Russia)
    • Party Type: entity

    Supplemental Information: None available.

    List of Changes:

    • Field Name: AKA
      • Changed: ZAKRYTOE AKTSIONERNOE OBSHCHESTVO (Cyrillic: ЗАКРЫТОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО СИБРЕГИОНГАЗ) to: ZAKRYTOE AKTSIONERNOE OBSHCHESTVO SIBREGIONGAZ (Cyrillic: ЗАКРЫТОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО СИБРЕГИОНГАЗ)

    —

    , ,