Venezuelan sanctions - OFAC issues various new General Licenses

Timeline of Key Events: January – February 2026

The following table summarizes key updates by the US since the seizure of Nicolas Maduro and the initial issuance of the new OFAC General Licenses:

Authorised Activities

Per Note 2 to GL 46A and OFAC FAQ 1227, authorised activities include:

• Commercial, legal, and technical discussions necessary to scope purchases, including with third-party consultants;
• Safety, environmental, and other inspections, including site surveys;
• Arranging logistics, security services, delivery points, and shipping preparation;
• Obtaining marine insurance and P&I coverage;
• Engaging with Venezuelan port or maritime authorities;
• Conducting downstream activities, including refining and resale;
• Coordinating payment structures, including payments in the form of swaps of oil, diluents, or refined petroleum products;
• Making required repairs and maintenance to pipeline, storage, or port infrastructure necessary to effectuate loading; and
• Financing of related cargoes or receivables.

Downstream Trading

OFAC FAQ 1235 confirms that once a transaction with PdVSA or a PdVSA Entity has been completed and the interest of the blocked entity is fully extinguished, the oil can be freely sold, resold, and traded by any downstream purchaser – including entities that are not established US entities. This is an important clarification for the secondary market in Venezuelan oil.

What GL 46A Does NOT Authorise

GL 46A expressly does not authorise:

• Payment terms that are not commercially reasonable, involve debt swaps, payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by the Government of Venezuela (including the petro);
• Transactions involving persons located in or organised under the laws of Russia, Iran, North Korea, or Cuba, or any entity owned or controlled by or in a joint venture with such persons;
• Transactions involving any Venezuelan or US entity that is owned or controlled by or in a joint venture with a person located in or organised under the laws of China (note: this does not prevent an established US entity from reselling Venezuelan oil to China);
• The unblocking of any property blocked under the VSR; or
• Transactions involving a blocked vessel.

GL 46A does not authorise exploration activity or negotiations for new investment, such as geological surveys, drilling, or negotiations to enter into contracts to develop or operate oil fields.

Commercially Reasonable Terms

OFAC FAQ 1232 defines "commercially reasonable terms" as terms consistent with prevailing market and industry standards for like or similar products produced by a company of similar size and scope, taking into account quality, quantity, pricing, performance, and safety, among others.

Mandatory Reporting

Any person that exports, re-exports, sells, resells, or supplies Venezuelan-origin oil to countries other than the US pursuant to GL 46A must file a detailed report with Sanctions_inbox@state.gov and VZReporting@doe.gov within ten days after the first such transaction, and every 90 days thereafter while transactions are ongoing. Reports must identify: (1) the parties involved; (2) quantities, values, and countries of ultimate destination; (3) dates of transactions; and (4) any taxes, fees, or other payments to the Government of Venezuela.

General License 48: Authorising the Supply of Certain Items and Services to Venezuela

Overview

GL 48 was issued on 10 February 2026. It authorises US persons and the provision from the United States of goods, technology, software, and services for the exploration, development, production, and maintenance of oil and gas operations in Venezuela – including the refurbishment or repair of items used in such activities.

Key Conditions

GL 48 includes the same core conditions as GL 46A: a US governing law and dispute resolution clause in contracts with Venezuelan state entities, and payment of monetary amounts to blocked persons (excluding local taxes, permits, and fees) into the Foreign Government Deposit Funds.

Authorised Activities

Authorised activities include:

• Processing of payments;
• Arranging shipping and logistics services, including chartering vessels;
• Obtaining marine insurance and P&I coverage;
• Arranging port and terminal services; and
• Maintenance of oil or gas operations, including refurbishment or repair of equipment.

What GL 48 Does NOT Authorise

GL 48 does not authorise:

• Non-commercially reasonable payment terms, debt swaps, gold payments, or Venezuelan digital currencies;
• Transactions involving persons in or organised under the laws of Russia, Iran, North Korea, Cuba, or China, or entities owned or controlled by or in a joint venture with such persons;
• Unblocking of blocked property;
• Transactions involving blocked vessels;
• Formation of new joint ventures or entities in Venezuela to explore or produce oil or gas; or
• Transactions related to the exportation or re-exportation of diluents, directly or indirectly, to Venezuela (this is addressed separately under GL 47).

Mandatory Reporting

Reports must be filed with Sanctions_inbox@state.gov and VZReporting@doe.gov within ten days of the first transaction and every 90 days thereafter, identifying parties, goods/technology/services (including quantities and values), dates, and payments to the Government of Venezuela.

General License 30B: Port and Airport Operations – Update on INEA

Background

Members will recall our Notice to Members No. 19 2020/2021 which addressed the designation by OFAC of Venezuela's Maritime Authority, the Instituto Nacional de los Espacios Acuaticos ("INEA"), under Executive Order 13850 for operating in the oil sector of Venezuela and providing assistance to PdVSA. That circular explained the confusion the designation created for shipowners calling at Venezuelan ports for trades unrelated to oil, and described the introduction of GL 30A (issued February 2021) which authorised transactions ordinarily incident to Venezuelan port operations, including dealings with INEA.

GL 30B Replaces GL 30A

On 10 February 2026, OFAC issued GL 30B, which replaces and supersedes GL 30A (dated 2 February 2021) in its entirety.

GL 30B continues the authorisation of transactions that are ordinarily incident and necessary to the operation or use of ports and airports in Venezuela – including dealings involving INEA or any entity in which INEA owns, directly or indirectly, a 50% or greater interest.

What is New in GL 30B?

OFAC FAQ 1236 confirms the key change: GL 30B removes the prohibition that was contained in GL 30A on transactions or activities related to the exportation or re-exportation of diluents to Venezuela. This prohibition is no longer relevant given that GL 47 separately authorises such transactions.

GL 30B expressly authorises:

• Payment of port fees and customs duties in connection with Venezuelan port and airport operations;
• Transactions involving INEA and its majority-owned subsidiaries; and
• Port and airport transactions in support of activities authorised under GL 46A, GL 47, and GL 48.

What GL 30B Does NOT Authorise

GL 30B does not authorise:

• Transactions otherwise prohibited by the VSR;
• Transactions with any blocked person other than INEA (or entities in which INEA owns 50% or more); or
• Dealings with any Government of Venezuela person that is blocked solely pursuant to EO 13884, unless separately authorised.

Non-US Persons and INEA

As was previously confirmed in the context of GL 30A, OFAC has indicated that non-US persons do not engage in sanctionable conduct by engaging in conduct that would be authorised by a General License if engaged in by a US person. As a matter of policy, the authorisation in GL 30B therefore applies by analogy to non-US persons.

Venezuela-related OFAC FAQs 1226–1237

OFAC has issued twelve FAQs (1226–1237) providing further guidance on the new General Licenses.

Guidance for Members

Members considering engagement in Venezuelan trade should note the following:

Tanker Owners / Operators:

• Shipowners chartering vessels to established US entities for the carriage of Venezuelan-origin oil are not required to be "established US entities" themselves. Non-US shipowners may provide transportation services ordinarily incident and necessary to a GL 46A transaction.
• Contracts between shipowners and the established US entity do not need to include US governing law or dispute resolution clauses – this requirement applies only to contracts directly with Venezuelan state entities.
• Voyages involving blocked vessels remain prohibited regardless of the license applicable to the cargo.
• INEA-related port dues and fees at Venezuelan ports continue to be authorised under GL 30B, including for voyages connected with GL 46A, 47, and 48 activities. Banking delays remain a practical risk; consult your bank in advance.

Due Diligence:

• Members must continue to conduct enhanced due diligence before engaging in any Venezuelan trade. In particular, Members should verify:
• That the party directly dealing with PdVSA or the Government of Venezuela qualifies as an "established US entity";
• That the vessel involved is not on the OFAC SDN list as a blocked vessel; and
• That no party in the transaction chain is located in or controlled by Russia, Iran, North Korea, Cuba, or (for GL 46A purposes) China.
• Financial institutions may rely on customer confirmations of GL compliance, but Members should be prepared to demonstrate compliance with applicable license conditions.

Conclusion

The issuance of multiple General Licenses since January 2026 represents a significant shift in US policy toward Venezuela's oil sector, selectively opening the door to US and allied participation in Venezuelan oil trade while maintaining a comprehensive sanctions framework and excluding the involvement of Russian, Iranian, North Korean, Cuban, and (in certain respects) Chinese parties.

The situation is evolving rapidly. OFAC continues to issue new FAQs and amend existing licenses. We will continue to monitor these developments closely and will issue further Notices to Members as the situation develops.

Important note

The information provided by the Club and in particular through its website is not and is not intended to be exhaustive. Every effort is made to ensure the accuracy of the information provided. However this cannot be guaranteed given that sanctions measures are subject to alteration by Governmental organisations at short notice. Further the information on this site is not, and should not be relied upon as, independent legal advice.

Members are strongly advised to undertake due diligence before fixing any business to or from a sanctioned country in order to ensure that neither the prospective cargo nor the parties to the planned venture are sanctioned. The Club is willing to assist Members where possible but they may nevertheless wish to take independent legal advice.