The Daily Journal. — The United States updated on Monday the licensing framework governing certain commercial and investment activities related to Venezuela’s oil, gas, petrochemical, and electricity sectors through General Licenses 46E, 48D and 49B issued by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC).
The new provisions replace previous versions of those licenses and establish the conditions under which U.S. companies may participate in activities involving Venezuelan crude oil, supply goods and services for energy operations, and negotiate agreements for potential investments in the country. The update comes as OFAC continues to modify the sanctions framework throughout 2026.
General License 46E allows U.S. companies established as of January 29, 2025, to conduct ordinary activities necessary for the extraction, exportation, reexportation, refining, marketing, transportation, and sale in the United States of Venezuelan-origin oil and petrochemical products.
The regulations maintain specific conditions for contracts with the Venezuelan government and Petróleos de Venezuela (Pdvsa), including provisions governing jurisdiction for dispute resolution and the destination of certain payments.
In particular, companies must direct monetary payments to blocked persons or entities — except for certain payments such as taxes, fees, and local permits — to foreign government deposit funds established under a U.S. executive order or to accounts designated by the Treasury Department. OFAC had previously established this mechanism for operations authorized under the oil license.
The license also establishes reporting requirements for certain transactions involving the sale or export of Venezuelan crude oil to third countries.
Goods and services for oil and electricity
General License 48D authorizes the supply from the United States, or by U.S. persons, of goods, technology, software, and services for oil, gas, and petrochemical exploration, development, and production activities in Venezuela.
Its scope also covers certain activities related to generating, transmitting, storing, and distributing electricity, as well as insurance services, maritime transportation, port operations, and the maintenance and repair of existing infrastructure.
OFAC, however, restricts the creation of new joint ventures under this license and sets conditions for transactions involving persons or entities from countries subject to certain U.S. restrictions. The agency had previously clarified that the license covering oil-related goods and services did not authorize the creation of new joint ventures to explore for or produce oil and gas.
Negotiating future investments
General License 49B allows potential investors to negotiate and enter into certain contingent contracts, binding offers, preliminary agreements, and memoranda of understanding related to future investments in the hydrocarbon and electricity sectors.
The license also covers commercial, legal, technical, and environmental assessments. However, investors must obtain specific OFAC authorization before moving forward with the investments.
This mechanism follows a structure Washington had already used to allow negotiations involving contingent investment agreements in Venezuela.
Financial restrictions
The new licenses maintain prohibitions on certain payment methods and financial transactions, including non-commercial transactions, debt swaps, payments in gold and transactions denominated in digital assets issued by or on behalf of the Venezuelan government, including the petro.
Restrictions also remain in place for certain persons and entities linked to Russia, Iran, North Korea and Cuba, as well as limitations on transactions involving blocked assets.
