Mr. Sanctions

Category: Venezuela

  • Burning Questions: In Plain Language – the 2 new OFAC Venezuela General Licenses

    So, what do Venezuela GL 56 & 57 mean?

    Background

    Venezuela is subject to broad U.S. sanctions, meaning most transactions with the Venezuelan government and its entities are prohibited by default. OFAC issues General Licenses to carve out specific exceptions — activities that are permitted without needing individual approval.

    General License 56 — Negotiating Contingent Contracts

    The core idea: You’re allowed to negotiate and draft contracts with the Venezuelan government, but you cannot actually execute or perform those contracts until you get separate OFAC approval.

    Think of it like being permitted to draw up a deal and shake hands, but the contract only becomes real once a regulator gives the green light.

    What’s covered: Any commercial negotiations with any part of the Venezuelan government — ministries, state agencies, state-controlled companies, or anyone acting on their behalf. “Contingent contracts” is defined broadly to include bids, proposals, MOUs, pro forma invoices, and similar preliminary agreements.

    Key restrictions — you cannot:

    • Negotiate contracts involving Venezuelan or PdVSA (state oil company) bonds or debt
    • Use non-standard payment terms — no gold payments, no debt swaps, no Venezuelan digital currency (the “petro”)
    • Enforce any legal judgments against blocked Venezuelan assets
    • Involve any parties from Russia, Iran, North Korea, or Cuba
    • Involve any entity owned or controlled by Chinese interests
    • Deal with anyone on OFAC’s SDN (blacklist) list

    General License 57 — Financial Services to Certain Venezuelan Banks

    The core idea: U.S. financial institutions and service providers can conduct normal financial transactions with or for four specific Venezuelan banks and ordinary Venezuelan government employees.

    The four banks covered:

    1. Banco Central de Venezuela (the central bank)
    2. Banco de Venezuela
    3. Banco Digital de los Trabajadores
    4. Banco del Tesoro

    Any entity majority-owned by these banks is also covered.

    Also covered: Individual Venezuelan government employees whose assets are technically “blocked” purely because they work for the government — as long as they are not on the SDN blacklist.

    What “financial services” means here is defined very broadly: account management, wire transfers, ACH payments, debit/credit cards, digital wallets, remittances, payroll processing, currency exchange, correspondent banking, securities, and more.

    Key restrictions:

    • This does not unblock any frozen assets
    • It doesn’t override any other sanctions rules
    • All normal Bank Secrecy Act and anti-money laundering obligations still apply

    Practical note for banks: A U.S. financial institution processing these transactions can rely on what the originating or receiving party tells them about compliance — as long as the bank has no reason to suspect something is wrong.

    How They Work Together

    GL 56 opens a path for businesses to explore and structure deals with Venezuela, while GL 57 enables the banking infrastructure needed to eventually support those deals. Neither license removes the requirement for further OFAC authorization before any real money moves on a new contract.

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  • April 16, 2026: OFAC Update 2, Part 2: Venezuela General Licenses & Frequently Asked Question

    From OFAC’s Recent Actions Notice:

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela,”:

    venezuela_gl56Download

    and Venezuela General License 57, “Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals.”

    venezuela_gl57Download

    OFAC is also issuing one Venezuela-related Frequently Asked Question, FAQ 1248.

    1248. Since January 2026, OFAC has issued a series of Venezuela-related General Licenses related to purchases and investment in Venezuela’s natural resource sectors, such as Venezuela-related General Licenses (GLs) 48A and 50A, that include a reporting requirement. Which parties are responsible for providing such reports pursuant to those General Licenses?

    Answer

    In general, the parties engaged in the primary authorized activity are responsible for complying with the applicable reporting requirements in these Venezuela-related GLs. Parties that are only indirectly involved or providing services ancillary to the primary authorized activity are not required to file reports pursuant to the applicable license. For example, a company providing services for the generation of electricity in Venezuela under GL 48A would need to report such activities pursuant to that license, but a bank processing payments related to those services does not also need to provide a report. Similarly, under GL 50A, the parties listed in the annex would be required to provide reports describing their activities undertaken pursuant to the license, whereas the bank processing those related payments would not.

    Date Released

    April 14, 2026

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  • April 14, 2026: OFAC Update 2, Part 1: OFAC Designation Removals

    Venezuela-related Designation Removal; Issuance of Venezuela-related General Licenses and Frequently Asked Question; Publication of Report for Licensing Activities Undertaken Pursuant to the Trade Sanctions Reform and Export Enhancement Act (TSRA)

    Delistings:

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

    OFAC Program: VENEZUELA Venezuela Sanctions Regulations, 31 C.F.R. part 591; Executive Order 13692; Executive Order 13808; Executive Order 13827; Executive Order 13835; Executive Order 13850; Executive Order 13857; Executive Order 13884

    MUNOZ PEDROZA, Reinaldo Enrique, Address: C. Gil Fortoul, Centauro A, 5-D, Santa Monica, Caracas, Distrito Capital 1040, Venezuela; DOB: 28 Nov 1971; POB: Caracas, Venezuela; Nationality: Venezuela; Gender: Male; Cedula No.: V-10869426 (Venezuela); Passport: 138050232 (Venezuela) expires 25 Jul 2021 (individual)

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  • 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.

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  • 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)

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  • 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

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  • 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

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  • 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

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  • 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

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  • 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

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