Background: Venezuela Sanctions Framework
The core U.S. sanctions against Venezuela have been in place for more than a decade, starting when Congress passed the Venezuela Defense of Human Rights and Civil Society Act, implemented through Executive Order (“EO”) 13692, which established the first country-specific program aimed at Venezuela. The first Trump Administration expanded U.S. sanctions, imposing, among other actions, debt-related restrictions on Petróleos de Venezuela, S.A. (“PdVSA”)—Venezuela’s state-owned oil company—along with the Government of Venezuela (“GoV”). Later, in 2019, as part of President Trump’s “maximum pressure” effort, OFAC designated PdVSA on the List of Specially Designated Nationals and Blocked Persons (“SDN List”) and then “blocked” the GoV, subjecting PdVSA, the GoV, and all Venezuelan state-owned entities to a U.S. asset freeze, cutting them from all transactions and dealings with U.S. persons, and creating significant secondary sanctions risk for non-U.S. persons if they engaged with any of these entities. In particular, this gave rise to significant restrictions on dealings with Venezuela’s oil and gas industry.
OFAC General Licenses Post-Maduro
Following the January 3, 2026, U.S. military operation in Caracas that resulted in the capture of Venezuelan President Nicolás Maduro and his transfer to the United States to face federal criminal charges, OFAC has significantly eased Venezuela-related sanctions. Specifically, OFAC has issued certain general licenses to promote trade and investment relating to Venezuela’s oil, gas, and minerals industries.
General License 46 / 46A / 46B — Venezuelan Oil and Petrochemical Exports
First published on January 29, 2026, and revised twice thereafter—on February 10, 2026 (as GL 46A) and March 13, 2026 (as GL 46B)—this general license permits an array of transactions tied to exporting Venezuelan-origin oil and importing petrochemical goods into the United States, each to be carried out exclusively by “established U.S. entities.” The license defines an “established U.S. entity” as “any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.”
The authorization under GL 46B covers crude oil, crude oil blends, and petroleum products within the meaning of FAQ 1226, along with petrochemical products as separately defined in the license text. Importantly, GL 46B’s reach does not extend to natural gas or to energy-related activities more broadly. GL 46B excludes any transaction that uses non-commercial or abnormal payment terms, such as debt swaps, gold payments, or digital currency issued by the Venezuelan government. The license also bars transactions involving Russia, Iran, North Korea, Cuba, or entities they own, control, or partner with, including certain Chinese-linked entities operating in Venezuela or the United States.
This update reviews the current state of Venezuela sanctions as the United States seeks to strike a balance between encouraging the GoV while ensuring that Venezuela does not backslide into activity contrary to U.S. policy. The use of these general licenses affords OFAC the flexibility to quickly snap back sanctions if U.S. policymakers determine that Venezuela has not made sufficient progress on key market-opening and human rights reforms.
Original Article: Venezuela Sanctions Update: Tracking OFAC General Licenses Post-Maduro — Jdsupra