New OFAC General Licenses set the stage for renewed US and international engagement in Venezuela’s energy sector
February 05, 2026
New OFAC General Licenses set the stage for renewed US and international engagement in Venezuela’s energy sectorFebruary 05, 2026 The Trump Administration has issued two new General Licenses (GLs) authorizing limited engagement in Venezuela’s oil trading sector. More licenses are anticipated in the coming days or weeks, affecting upstream and downstream activities in the oil, natural gas, and possibly other sectors. First, GL 46 reopens Venezuela’s oil sector to authorized companies trading in Venezuelan-origin oil, subject to certain limitations.
GL 46 does NOT authorize:
If Venezuelan-origin oil is exported or supplied to destinations outside the United States, companies must submit by email detailed reports within ten days, and every 90 days thereafter if the transaction is ongoing. Information required in the reports include:
On the heels of GL 46, on February 3, OFAC issued GL 47 authorizing US-origin diluent supplies to Venezuela. Venezuela’s oil production is dominated by extra‑heavy crude from the Orinoco Belt, a resource so thick and asphalt‑like that it cannot flow, be transported, or be exported without adding lighter hydrocarbons known as diluents. The entire modern Venezuelan production system depends on reliable access to these inputs. GL 47 authorizes all transactions ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, marketing, delivery, or transportation of US-origin diluents to Venezuela and involving the GoV, PdVSA, or related entities, provided that the contracts are governed by US law and any dispute resolution occurs in the United States. GL 47 retains some of the same restrictions found in GL 46, including the prohibition on payments involving debt swaps. GL 47 also prohibits non–commercially reasonable payment terms; payments in gold or in digital currency issued by or for the GoV; transactions involving persons located in or organized under the laws of Iran, North Korea, Cuba, or entities they own or control; the unblocking of any previously blocked property; and transactions involving blocked vessels. Taken together, GLs 46 and 47 signal a cautiously expanding pathway for future international engagement in Venezuela’s energy and other sectors, suggesting that additional openings may emerge as regulatory conditions continue to evolve. __________ If you have any questions about this Legal Briefing, please feel free to contact any of the attorneys listed or the Eversheds Sutherland attorney with whom you regularly work. Latest InsightsLatest News
Latest Events
legal updates July 20, 2026 Industrials Unpacked #1: Supply Chain Contracts legal updates July 17, 2026 EU Forced Labour Regulation legal updates July 16, 2026 Trump v Slaughter: What the US Supreme Court’s ruling means for transatlant... legal updates July 10, 2026 Global Sustainability & ESG Insights - June 2026 firm news July 10, 2026 Eversheds Sutherland advises OCBC on the landmark secondary dual listing of... client news July 10, 2026 Setting sail: Eversheds Sutherland advises senior management of D-Marin on ... client news July 09, 2026 Eversheds Sutherland advises Costello Medical on transition to employee own... firm news July 01, 2026 Eversheds Sutherland lands lateral partner-led Paris Funds team, as its wid... virtual UAE - Employment law in the Dubai International Financial Centre September 10, 2026 9.30am - 1.30pm (GMT) Virtual in-person Managing AI use in the workplace: what every UK HR team needs to know September 10, 2026 9.30am - 1.00pm (BST) London, United Kingdom in-person Basic foundations of US employment law September 17, 2026 9.30am - 4.30pm (GMT) London, United Kingdom in-person 2026 BDC Roundtable September 23, 2026 Washington DC, United States |