Insights

Since the U.S. military’s abrupt capture of Venezuelan President Nicolás Maduro on January 3, 2026, the Trump administration has authorized many activities involving Venezuela that were previously prohibited under U.S. sanctions. Specifically, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued numerous General Licenses (GLs) affecting the country’s energy and minerals sectors and allowing for greater participation by U.S. persons.

Background

U.S. economic sanctions against Venezuela are governed by the Venezuela Sanctions Regulations (VSR), which implement and expand upon various executive orders (EOs). These EOs include EO 13692 of 2015, which declared a national emergency related to the situation in Venezuela; EO 13808 of 2017, which prohibited certain financial transactions with the Government of Venezuela and state-owned Petróleos de Venezuela, S.A. (PdVSA); EO 13850 of 2018, which allowed for the blocking of property of additional persons in Venezuela, including persons operating in the gold sector and persons responsible for or complicit in corruption; and EO 13884 of 2019, which blocked property of the Government of Venezuela, including the Central Bank of Venezuela and PdVSA. Taken together, the EOs and VSR create the legal and regulatory foundation for sanctions against Venezuela.

Over the past decade, Venezuela’s energy industry, monopolized by PdVSA, has been targeted and severely limited by OFAC sanctions actions. But the country has not been subject to comprehensive sanctions similar to those imposed on Iran, Cuba, or North Korea. During the Biden administration, U.S. oil giant Chevron benefited from a general license (GL 41), which essentially acted as an exception to sanctions prohibitions, allowing for Chevron’s continued oil extraction in Venezuela. Near the beginning of the second Trump administration, OFAC revoked GL 41, severing Venezuela’s remaining tie to the U.S. oil industry and eliminating a continuing source of investment in the country’s neglected energy infrastructure.

Oil & Gas and Energy General Licenses

After the dramatic capture of Maduro and subsequent engagement with Venezuela’s acting president, Delcy Rodríguez, OFAC issued several GLs to allow for U.S. re-entrance into Venezuela’s energy industry.

General License 46B

GL 46B is an updated version of GL 46, originally issued on January 26, 2026. See our previous Trade Alert describing GL 46, OFAC Issues New General License Authorizing Certain Venezuela Oil Transactions. Whereas the original GL 46 related only to oil, the reissued version also authorizes transactions related to other Venezuelan-origin petrochemical products, including fertilizer products and fertilizer precursor chemicals.

As is the case for the original GL 46, transactions pursuant to GL 46B require 1) contracts with the Government of Venezuela, PdVSA, and entities owned 50% or more by PdVSA (PDVSA Entities) to specify that U.S. law governs the contract and dispute resolution must occur in the United States; and 2) payment to blocked funds must be made into Foreign Government Deposit Funds, although this requirement now excludes payments for local taxes, permits, or fees.

Additionally, transactions authorized by 46B must involve an “established U.S. entity,” which means “any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.” Any person subject to OFAC jurisdiction that exports, reexports, sells, resells, or supplies Venezuelan-origin oil to countries other than the United States pursuant to GL 46B must also report details regarding the specific activity to the Department of State and the Department of Energy.

Payment terms for transactions authorized by GL 46B must be “commercially reasonable,” which OFAC has defined as “consistent with prevailing market and industry standards for like or similar products produced by a company of similar size and scope, while taking into account characteristics such as quality, quantity, pricing, performance, and safety, among others.” Further, GL 46B does not authorize transactions involving Russian, Iranian, Cuban, or North Korean persons or entities owned, controlled, or in a joint venture with such persons. GL 46B similarly does not authorize transactions with Venezuelan or U.S. entities that are owned, controlled, or in a joint venture with individuals or entities located in or organized under the laws of the People’s Republic of China (PRC).

General License 47

GL 47, Authorizing the Sale of U.S.-Origin Diluents to Venezuela, issued on February 3, 2026, allows for U.S. persons to participate in transactions with Venezuela, PdVSA, and PdVSA Entities involving U.S.-origin diluents. Per OFAC a “diluent” means “a light hydrocarbon liquid, such as natural gas condensate, naphtha, or light crude oil, that is added to heavy crude oil or bitumen to reduce its viscosity and density in order to transport, export, store, or process more easily.” GL 47 contains restrictions and requirements similar to 46B, including commercially reasonable payment terms, a restriction against transactions with Iranian, Cuban, or North Korean persons, and reporting requirements.

General License 48A

Originally issued on February 10, 2026, and revised on March 13, 2026, GL 48A authorizes the Supply of Certain Items and Services to Venezuela, when those items and services are “ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, or production of oil, gas, or petrochemical products in Venezuela, or for the generation, transmission, storage, or distribution of electricity in Venezuela.” The March 13 revisions added the authorizations related to petrochemical products and electricity.

GL 48A also contains contractual, dispute resolution, payment, and reporting requirements. Notably, GL 48A does not authorize the formation of new joint ventures in Venezuela for the exploration or production of oil and gas.

General License 49A

GL 49A, issued on March 13, 2026, and revising the original GL 49, authorizes Negotiation and Entry Into Contingent Contracts for “new investment in oil, gas, petrochemical products, or electricity sector operations in Venezuela.” Importantly, the performance of the subject contracts is contingent upon separate authorization by OFAC. Similar to GL 48A, the revised 49A added authorizations related to the Venezuelan petrochemicals and electricity sectors. GL 49A also contains restrictions against transactions involving Russian, Iranian, North Korean, Cuban, and PRC entities or individuals.

General License 50A

Issued on February 18, 2026, GL 50A is similar to the original GL 46 in that it authorizes Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities. Whereas GL 46B generally authorized oil transactions and was later revised to add petrochemical products, GL 50A authorizes only oil or gas sector operations involving entities specified on an Annex to GL 50A. The six listed entities are:

• BP PLC,

• Chevron Corporation,

• Eni S.p.A.,

• Établissements Maurel & Prom SA,

• Repsol S.A., and

• Shell PLC

GL 50A has similar requirements and restrictions to GLs 46B and 48A.

General License 30B

GL 30B is a February 10, 2026, update to GL 30A, issued on February 2, 2021. GL 30B authorizes Certain Transactions Related to Port and Airport Activities. Specifically, GL 30B removes a provision in GL 30A that restricted the use of Venezuelan ports and airports for exportation or reexportation of diluents, directly or indirectly, to Venezuela. This revision was required pursuant to the authorizations for the exportation of U.S.-origin diluents to Venezuela contained in GL 47 discussed above.

General Licenses 52

On March 18, 2026, OFAC issued GL 52, Authorizing Certain Transactions Involving PdVSA, which more broadly authorizes transactions by “established U.S. entities” with PdVSA and PdVSA Entities that are otherwise prohibited by EOs 13884 and 13850. GL 52 maintains the same contractual, payment, and reporting requirements as other similar GLs but also contains additional restricted transactions that are explicitly not authorized. For example, GL 52 does not authorize certain transactions related to bonds and certain other debt of the Government of Venezuela or PdVSA, or certain transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela of any equity interest in PdVSA, PdVSA Entities, or any other entity that is 50% or more owned by the Government of Venezuela.

Gold and Other Minerals General Licenses

Venezuelan sanctions relaxation goes beyond the energy sector. Many recent GLs also authorize activities related to the Venezuelan minerals sector with a special emphasis on Venezuelan gold.

General License 51A

Pursuant to GL 51, dated March 6, 2026, OFAC authorized certain activities related to Venezuelan gold. On March 27, 2026, OFAC issued GL 51A, expanding the authorization to include “activities involving Venezuelan-origin minerals, including gold.” OFAC has authorized transactions involving the Government of Venezuela, CVG Compania General de Mineria de Venezuela CA (Minerven), or any entity owned 50% or more by Minerven (Minerven Entities), “that are ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin minerals, including gold.”

Similar to GL 46B, transactions authorized by GL 51A must be undertaken by an “established U.S. entity.” GL 51A’s requirements and restrictions are similar to those in GL 46B and include certain contractual, payment, and reporting obligations.

General Licenses 54

On March 27, 2026, OFAC further authorized via GL 54 activities related to Venezuela’s mineral sector by allowing for the Supply of Certain Items and Services for Minerals Operations in Venezuela. Similar to GL 51A, GL 54 authorizes certain transactions with the Government of Venezuela, Minerven, and Minerven Entities. The impact of GL 54 operates for Venezuela’s mineral industry like the operation of GL 48A with respect to Venezuela’s oil, gas, petrochemical products, and electricity industries.

General License 55

Lastly, for now, OFAC issued GL 55 on March 27, 2026 to authorize Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Minerals Sector. GL 55 is the equivalent of GL 49A but for Venezuela’s mineral sector and Minerven rather than the oil, gas, petrochemical product, and electricity sectors and PdVSA.

Export Controls

Nearly all the above GLs explicitly state that the GL does not relieve any person of compliance with export control requirements of the Department of Commerce Bureau of Industry and Security (BIS). Economic sanctions and export control frameworks work independently in this instance. Companies wishing to take advantage of the new regulatory environment related to Venezuelan energy and minerals must ensure separate export control authorization is not required, or, if authorization is required, obtain such authorization.

In addition to general export control compliance (e.g., item classification, denied party screening, and license authorization), exporters must remember the stricter electronic export information (EEI) requirements for exports to Venezuela. Namely, all items listed on the Commerce Control List generally require EEI filings when exported to Venezuela regardless of value.

Risks

There are significantly more opportunities for U.S. persons to engage in transactions and investments in the Venezuelan oil and gas, petrochemical, electricity, and mineral sectors since the beginning of the year. The GLs above authorize engagement in these sectors as well as certain tangential services and activities. But any companies seeking to take advantage of the new opportunities must be prepared to navigate significant risk.

Sanctions and Export Control Risks

The GLs have multiple restrictions that will require due diligence of transaction parties to ensure no involvement of denied or restricted parties based on either sanctions or export control listings (e.g., the Specially Designated Nationals (SDN) List or the BIS Entity List) or restricted country involvement (i.e., PRC, Russian, Cuban, Iranian, or North Korean persons). The GLs also have specific requirements related to payment, dispute resolution, and reporting. Failure to adhere to any of these requirements could negate the general license, opening the violating party up to enforcement actions from OFAC.

Importantly, the relaxation with respect to Venezuela also does not absolve violations that occurred prior to the effective date of OFAC GLs authorizing certain transactions. As an example, Syria recently underwent sanctions relaxation as discussed in our previous article, U.S. Relaxes Syria Sanctions. Despite this relaxation, OFAC continues to bring enforcement actions against violations that occurred prior to the authorization of transactions with Syria, including a February 25, 2026 enforcement action against a U.S. person for violations of the Syrian Sanctions Regulations “when U.S. sanctions on Syria were in place.” For that reason, companies or individuals that discover sanctions violations that occurred prior to the Venezuelan relaxation should weigh the risks and benefits of voluntarily disclosing the conduct to OFAC.

Corruption Risks

In addition to sanctions risk, the operating environment in Venezuela presents many risks that could trigger Foreign Corrupt Practices Act (FCPA) violations. Although the Department of Justice (DOJ) notably issued a “pause” on FCPA enforcement in early 2025, this pause has since ended. And the first FCPA action announced by the DOJ after the pause involved a bribery scheme related to a state-owned Latin American oil company, albeit in Mexico rather than Venezuela.

Venezuela is no stranger to FCPA enforcement. In November 2024, a Venezuelan subsidiary of Spanish telecom company Telefónica S.A. settled with DOJ for $85.2 million to resolve the DOJ’s investigation of a scheme whereby Telefónica bribed Venezuelan officials to gain access to a government auction to exchange Venezuelan bolivars for U.S. dollars. The FCPA jurisdiction stemmed from the Venezuelan subsidiary, Telefónica Venezolana C.A., being a “a subsidiary and agent of a U.S. issuer,” highlighting the FCPA exposure for non-U.S. companies.

Latin America, the oil and gas industry, and the mining and minerals sector are historical hotbeds of FCPA violations and enforcement. Introducing new opportunities for investment and business in what remains the poorest country in South America is an invitation for anti-bribery risk. Companies interested in activity in Venezuela should ensure they are well-versed in FCPA requirements and compliance prior to establishing new business in the region.

After sanctions relaxation, there are more opportunities for U.S. persons in the Venezuelan economy now than there have been for several years. But entry into this area comes with certain risks, so businesses should remain cautious and continue to conduct intensive due diligence related to any new activity in the country. If you have any questions about Venezuelan sanctions, export controls, or anti-bribery risks, please do not hesitate to contact the attorneys at Torres Trade Law.