OFAC Issues New General Licenses Expanding Permitted Activities in the Venezuelan Energy Sector

During the first half of February 2026, only a few weeks after the US capture of former Venezuelan President Nicolas Maduro, the US government has swiftly moved to significantly expand the range of activities that US companies can conduct in connection with the Venezuelan energy sector. To that end, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued a flurry of new general licenses (“GLs”), on February 3 (GL 47), February 10 (GL 48), and February 13 (GL 49 and GL 50).

Subject to certain conditions and limitations, these GLs authorize, respectively, (1) the sale of US-origin diluents to Venezuela; (2) the supply of goods, services, technology and software for the exploration, development, or production of oil or gas in Venezuela; (3) the negotiation and entry into contingent contracts for investments in the South American country’s oil or gas sectors; and (4) for certain specified oil companies and their subsidiaries, broadly all transactions related to oil or gas sector operations in Venezuela. OFAC also amended GL 46—which authorizes Venezuelan oil trading and a swath of midstream and downstream activities as discussed in our prior Legal Update—to allow payment of local taxes, permits and fees to the Government of Venezuela in connection with the authorized activities, so long as all other monetary payments are deposited in Foreign Government Deposit Funds (GL 46A).

Together, these authorizations represent the most significant easing of US sanctions restrictions on Venezuela in several years.  While these authorizations open up business opportunities for market participants, the US sanctions against the Government of Venezuela, its agencies and instrumentalities (collectively, the “Government of Venezuela”) as well as PDVSA and its majority-owned affiliates (“PDVSA” and collectively “PDVSA Entities”) remain in place, and companies must carefully assess and manage the compliance risks associated with seizing such opportunities.

This Legal Update is the fourth in a series addressing the rapidly evolving Venezuela-related legal landscape. It follows our earlier Legal Updates on Executive Order 14373, which shields Venezuelan oil revenue held in US Treasury accounts from judicial process; Venezuela’s Transformation of its Hydrocarbons Sector with a New Hydrocarbons Law Amendment, which opens new pathways for private sector participation in the country’s energy sector; and GL 46, authorizing established US companies to engage in a broad range of activities involving Venezuelan oil.

Scope, Conditions and Limitations of GL 47 (Sale of US Origin Diluents)

Scope: GL 47 authorizes transactions ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, marketing, delivery, or transportation of US-origin diluents to Venezuela, including transactions involving the Government of Venezuela and PDVSA Entities.
Conditions: Parties relying on GL 47 must ensure that any contract with the Government of Venezuela or PDVSA Entities specify that:

• The contract is governed by the laws of the US or any jurisdiction within the United States; and
• Any dispute resolution under the contract must occur in the US;

Limitations: GL 47 expressly states that it does not authorize any of the following:

• Prohibited Payment Terms: Payment terms that are not commercially reasonable, or that involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela;
• Parties from Prohibited Countries: This includes parties located in or organized under the laws of Iran, North Korea, or Cuba, as well as their owned or controlled entities and joint ventures;
• Unblocking of Blocked Property: In keeping with OFAC’s customary practice when issuing authorizations, the license does not authorize unblocking of blocked property; and
• Blocked Vessels: Transactions involving a blocked vessel.

Reporting Requirements: Parties relying on GL 47 must report details of the transaction to the US State and Energy Departments 10 days after execution of the first transaction and every 90 days thereafter for ongoing transactions. Required transaction details include the parties involved, quantities and values of the transactions, and the transaction dates.

Scope, Conditions and Limitations of GL 48 (Supply of Certain Items and Services)

Scope: GL 48 authorizes transactions ordinarily incident and necessary to the provision, from the US or by US persons, of goods, technology, software, and services for the exploration, development, production, and maintenance of oil and gas operations in Venezuela.

Conditions: Parties relying on GL 48 must ensure that:

• Any contract with the Government of Venezuela or PDVSA Entities specify that the contract is governed by the laws of the United States or any jurisdiction within the United States, and any dispute resolution under the contract must occur in the United States; and
• Any monetary payment to a sanctioned person must be deposited into accounts of the US Department of the Treasury as described in Executive Order 14373 or any other account as instructed by the US Department of the Treasury with the only exception of payments of local taxes, permits or fees.

Limitations: GL 48 expressly states that it does not authorize any of the following:

• Prohibited Payment Terms: Payment terms that are not commercially reasonable, or that involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela;
• Parties from Prohibited Countries: This includes parties located in or organized under the laws of Russia, Iran, North Korea, Cuba, or China, or their owned or controlled entities and joint ventures;
• Unblocking of Blocked Property: In keeping with OFAC’s customary practice when issuing authorizations, the license does not authorize unblocking of blocked property;
• Blocked Vessels: Transactions involving a blocked vessel;
• New Joint Ventures: The formation of new joint ventures or other entities in Venezuela to explore or produce oil or gas; and
• Diluents: Any transactions or dealings related to the exportation or reexportation of diluents directly or indirectly to Venezuela, which is only authorized as set forth in GL 47.

Reporting Requirements: Parties relying on GL 48 must report details of the transaction to the US State and Energy Departments 10 days after execution of the first transaction, and every 90 days thereafter for ongoing transactions. Required transaction details include the parties involved, the goods, technology software or services involved, including quantities and values, the transaction dates, and any taxes, fees, or other payments provided to the Government of Venezuela.

Scope, Conditions and Limitations of GL 49 (Contingent Investment Contracts)

Scope: GL 49 authorizes all transactions that are related to the negotiation of and entry into contingent contracts for new investments in oil or gas sector operations in Venezuela, including contracts to engage in the following activities in Venezuela:

• New oil or gas exploration, development, or production activities;
• Expansion of existing operations;
• Formation of new joint ventures or other entities; and
• Prefatory steps to new investments including conducting commercial, legal, technical, safety, and environmental due diligence and assessments.

Contingent contracts for these purposes includes executory contracts executory pro forma invoices, agreements in principle, executory offers capable of acceptance such as bids or proposals in response to public tenders, binding memoranda of understanding or any other similar agreement.

Conditions: Parties relying on GL 49 must ensure that the performance of any contract for new investment in oil or gas sector operations in Venezuela is made expressly contingent upon separate OFAC authorization.

Limitations: GL 49 expressly states that it does not authorize any of the following:

• Transactions Involving Parties from Prohibited Countries: This includes parties located in Russia, Iran, North Korea, Cuba or China or their owned or controlled entities and joint ventures;
• Unblocking of Blocked Property: In keeping with OFAC’s customary practice when issuing authorizations, the license does not authorize unblocking of blocked property; and
• Blocked Vessels: Transactions involving a blocked vessel.

Scope, Conditions and Limitations of GL 50 (Oil and Gas Operations for Specified Companies)

Scope: GL 50 authorizes all transactions related to oil or gas sector operations in Venezuela of specified entities listed in the Annex to the GL, including certain US, UK, Italian, Spanish and Dutch oil companies and their subsidiaries.

Conditions: Parties relying on GL 48 must ensure that:

• Any contract with the Government of Venezuela or PDVSA Entities specify that the contract is governed by the laws of the United States or any jurisdiction within the United States, and any dispute resolution under the contract must occur in the United States; and
• Any monetary payment to a sanctioned person must be deposited into accounts of the US Department of the Treasury as described in Executive Order 14373 or any other account as instructed by the US Department of the Treasury. The only exception to this requirement applies to payments of local taxes, permits or fees not including oil or gas taxes or royalties to the Government of Venezuela or PDVSA Entities.

Limitations: GL 50 expressly states that it does not authorize any of the following:

• Prohibited Payment Terms: Payment terms that are not commercially reasonable, or that involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela;
• Parties from Prohibited Countries: This includes parties located in Russia, Iran, North Korea, Cuba or China or their owned or controlled entities and joint ventures;
• Unblocking of Blocked Property: In keeping with OFAC’s customary practice when issuing authorizations, the license does not authorize unblocking of blocked property; and
• Blocked Vessels: Transactions involving a blocked vessel.

Reporting Requirements: Parties relying on GL 50 must report details of the transaction to the US State and Energy Departments 10 days after execution of the first transaction and every 90 days thereafter for ongoing transactions. Required transaction details include the parties involved, a description of the transactions, including quantities and values, the transaction dates, and any taxes, fees, or other payments provided to the Government of Venezuela.

Amendment to GL 46A to Allow for Certain Monetary Payments to Venezuelan Sanctioned Persons

OFAC has amended GL 46, now GL 46A, to carve out an exception to the general requirement that any monetary payment to sanctioned persons, including the Government of Venezuela and PDVSA Entities must be made into US Treasury controlled accounts. The exception in question is to allow for payment of local taxes, permits and fees to the Government of Venezuela in connection with the authorized activities. Otherwise, GL 46A reflects the same scope, conditions and limitations set forth in GL 46 and discussed in our prior Legal Update discussing this GL.
Additionally, OFAC has issued 10 new FAQs to clarify the scope of GL 46.

Conclusion

The issuance of the GLs described above marks a meaningful evolution in the US sanctions regime toward Venezuela, particularly in relation to the oil and gas sector. While these authorizations create new pathways for engagement—including trade, services, and potential investment arrangements—they are accompanied by stringent eligibility criteria, contractual safeguards, reporting requirements, and continuing sanctions risks. Entities considering reliance on these GLs should conduct thorough transactional and sanctions analyses and due diligence, incorporate robust compliance controls, and monitor for further regulatory developments. The sanctions landscape remains fluid, and additional authorizations or guidance may be forthcoming. In particular, companies should watch for additional OFAC FAQs addressing interpretive questions raised by the new licenses.

Concurrent requirements under Commerce, State, Department of Energy and other agencies should be assessed before engaging in covered activities. Additionally, as discussed in our prior Legal Update on Venezuela's proposed amendments to its Organic Law on Hydrocarbons, Venezuela's legal framework for oil sector investment is also undergoing significant changes. Companies should consider both the US sanctions landscape and Venezuela's domestic legal environment when evaluating potential investments and activities.

Mayer Brown is closely monitoring developments and will continue to publish Legal Updates on significant changes. Please contact any of the authors or your usual Mayer Brown contact for further guidance.