Category: Venezuela

  • Yes, OFAC’s Venezuela GL 5 is up to the Y revision:

    and there is an updated FAQ 595, too

    595. What does Venezuela-related General License 5Y 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    General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license.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 5Y on August 3, 2026, which further delays the effectiveness of the authorization in GL 5 until September 17, 2026. Between October 24, 2019 and September 17, 2026 (the date the authorization in General License 5Y 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: August 03, 2026

    Date Released

    January 20, 2022

  • Today, OFAC issued Russian-related General License 131H:

    and amended related Frequently Asked Questions 1224:

    1224. What negotiations does Russia-related General License 131H 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) 131H, 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 131H expires on August 22, 2026.

    GL 131H 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 131H 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 131H 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: July 24, 2026

    Date Released

    November 19, 2025

    and 1225:

    1225. What activities do Russia-related General License 128C and General License 131Hauthorize 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 131H. The GLs are similar but have different expiration dates and terms as each serves a different purpose.

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

    GL 128C and GL 131H 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 131H. 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 131H 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 131H 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 131H. Similarly, non-U.S. persons may rely upon GL 128C and GL 131H regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128C and GL 131H, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

    Date Updated: July 24, 2026

    Date Released

    December 4, 2025

    as well as Venezuela FAQ 1239:

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

    Answer

    To obtain payment account information for payments to the Foreign Government Deposit Funds deposit account established consistent with 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, depositors must first email the official point of contact for the deposit account at: DepositorInquiries@state.gov. Potential depositors that fail to contact this email inbox and provide the requested transaction details may have their deposits rejected. Potential depositors should 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(s);
    • 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.

    Once the Department of State has provided payment account information and the deposit has been made and accepted, the depositor will receive a confirmation email acknowledging the deposit, which can be used to inform all contract parties involved in the transaction.

    Date Updated: July 24, 2026

    Date Released

    March 4, 2026

    Finally, OFAC issued a new final rule:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is adopting a final rule to update website and contact information in certain parts of the Code of Federal Regulations (CFR). Additionally, OFAC is amending one CFR part to update general licenses authorizing payments for legal services from funds originating outside the United States to replace the reporting requirement in the general license with a recordkeeping requirement and correcting typographical errors in two CFR parts. OFAC is also updating a part of 31 CFR chapter V to correct an erroneous cross-reference.

    Here’s the final rule:

  • It’s FAQ 1263:

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

    Answer

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

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

    Date Released

    July 17, 2026

  • It’s General License 60 (Authorizing Transactions Related to Earthquake Relief Efforts in Venezuela):

  • The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Venezuela-related General License 5X, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After August 4, 2026;” Venezuela-related General License 24A, “Certain Transactions Involving the Government of Venezuela Related to Telecommunications and Mail Authorized;” and Venezuela-related General License 59, “Authorizing the Supply of Certain Items and Services Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A. (Conviasa).”

    Additionally, OFAC is amending one Venezuela-related Frequently Asked Question, FAQ 595.

    New versions: GL 5X:

    and GL 24A:

    And new GL 59:

    And here’s the amended FAQ:

    595. What does Venezuela-related General License 5X authorize? 

    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 5X on June 18, 2026, which further delays the effectiveness of the authorization in GL 5 until August 4, 2026. Between October 24, 2019 and August 4, 2026 (the date the authorization in General License 5X 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: June 18, 2026

    Updated on Jun 18, 2026

  • Here’s what OFAC said:

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Venezuela-related General License 46C, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;” Venezuela-related General License 47A, “Authorizing the Sale of U.S.-Origin Diluents to Venezuela;” Venezuela-related General License 48B, “Authorizing the Supply of Certain Items and Services to Venezuela;” Venezuela-related General License 50B, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities;” Venezuela-related General License 51B, “Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold;” Venezuela-related General License 52A, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.;” and Venezuela-related General License 54A, “Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela.”

    Additionally, OFAC is issuing two Venezuela-related Frequently Asked Questions, FAQs 1259 and 1260.

    Let’s go backward this time – here are the FAQs:

    1260. Does the requirement in certain Venezuela General Licenses (e.g., 46C, 47A, 48B, 50B, 51B, 52A, and 54A) that the terms of contracts be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States mean that U.S. law must govern all aspects of the underlying activity? 

    No.  Certain Venezuela general licenses (GLs) require that any contract for transactions authorized by the GL with the Government of Venezuela or certain other covered entities (e.g., Petróleos de Venezuela, S.A. in GL 52A or CVG Compañía General de Minería de Venezuela CA in GL 51B) specify that the terms of the contract be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States. The GLs also require dispute resolution proceedings relating to the contract or its breach to occur in the United States, the United Kingdom, France, or Singapore. If the parties agree to submit their dispute to arbitration, the procedural rules applicable are those rules agreed by the parties, or the rules of internationally recognized institutions or the rules of the seat of arbitration.

    This requirement means that the laws of a state or other jurisdiction within the United States must govern questions of contract law between the parties relating to the contract, including interpretation, contractual performance obligations, breach, contractual remedies, payment obligations, termination, validity, assignment or novation, and enforceability of the contract.

    The requirement permits the inclusion of contract terms that recognize that certain aspects of the underlying activity in Venezuela may be subject to applicable Venezuelan law and regulations, including laws and regulations governing the exercise of Venezuela’s sovereign regulatory authority, administrative permits and licenses, concessions, labor, environmental, health and safety, and other mandatory regulatory requirements.

    Released on Jun 10, 2026

    Venezuela Sanctions

    1259. Are private and commercial flights authorized to arrive in and depart from airports in Venezuela, and can they receive ground services in-country? 

    Yes. Venezuela-related General License (GL) 30B authorizes U.S. persons to engage in all transactions involving the Government of Venezuela (GOV), including its agencies and instrumentalities like the Instituto Nacional de Aeronáutica Civil (INAC) and Instituto Nacional de los Espacios Aquaticos (INEA), that are ordinarily incident and necessary to the operation or use of airports in Venezuela.

    Transactions ordinarily incident and necessary to the operation or use of airports in Venezuela include but are not limited to: the provision of baggage and ground handling services; safety and security services; airport operational services; air navigation and overflight services; fuel and into-plane services; and the payment of aeronautical, customs, immigration, and other government-imposed fees and taxes. Please see FAQ 1236 for additional information on GL 30B’s authorizations.

    GL 30B does not authorize transactions involving blocked persons other than (i) INEA, or (ii) GOV persons blocked solely pursuant to E.O. 13884, including INAC.

    Additionally, Venezuela-related GL 33 authorizes the receipt of, and payment for, services involving the GOV related to overflights and emergency landings in Venezuela. It also authorizes transactions necessary to provide air ambulance and related medical services, including medical evacuation.

    GL 33 does not authorize transactions involving persons identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) or owned 50 percent or more by persons identified on the SDN List.

    Generally, non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized for U.S. persons, including engaging in transactions authorized pursuant to GL 30B or GL 33. Additionally, U.S. sanctions programs issued pursuant to the International Emergency Economic Powers Act (IEEPA), including the Venezuela Sanctions Regulations, do not generally prohibit transactions ordinarily incident to travel to or from any country.

    Released on Jun 10, 2026

    and the GLs:

  • I’m happy to report that someone reads this old blog – Francisco Ramos M. does! He wrote me to tell me that my CAATSA Practitioners’ Guide inspired him to try his hand at one, too. Here it is – clearly aimed at a different audience (nothing wrong with that).

    Here’s his English version:

    and his Spanish:

    I had Claude compare the two English versions, and it gave us both some very helpful feedback – including the fact that my version does not take into account Venezuelan regulations and Francisco’s does.

    Of course, we’d love your feedback… hint, hint.

  • Again, there will also be a Spanish language version later once I get done with some grammar and terminology fixed… in the meantime, the English version: