On January 29, 2026, the Office of Foreign Assets Control (OFAC) issued General License No. 46, which, without constituting a general lifting of sanctions against Venezuela, authorizes, in a limited manner and subject to strict conditions, certain transactions related to Venezuelan-origin oil.
The license authorizes certain already established U.S. entities to carry out activities related to the extraction, exportation, transportation, marketing, refining, and purchase of Venezuelan crude oil, even when such activities involve the Government of Venezuela, Petróleos de Venezuela, S.A. (PDVSA), or companies owned or controlled by the state-owned oil company, provided that a rigorous set of contractual and financial requirements is met.
Among the key conditions established by OFAC are the following:
- Contracts must be governed by U.S. law, and any disputes must be resolved before courts in the United States.
- Payments made to blocked persons or entities may not be freely disposable and must be channeled through funds designated by the U.S. Department of the Treasury.
- Payments in gold, cryptocurrencies, or non-commercial arrangements are expressly prohibited, as are transactions involving actors from Russia, Iran, North Korea, or Cuba, entities controlled by China, or vessels included on sanctions lists.
Additionally, the license imposes strict reporting obligations for exports of Venezuelan crude oil to third countries, with the aim of strengthening oversight and traceability of authorized operations.
