The Daily Journal.— The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) expanded its authorization Monday to allow certain U.S. companies to conduct transactions with Petróleos de Venezuela (PDVSA) and its majority-owned subsidiaries, marking another easing of the sanctions framework governing operations with Venezuela’s oil sector.
General License 52C, which OFAC issued on Sept. 14, 2026, contains the new measures and fully replaces General License 52B, dated Aug. 27.
The new license authorizes U.S. entities incorporated in the United States or under the laws of any U.S. jurisdiction on or before Jan. 29, 2025, to conduct transactions that Executive Orders 13884 and 13850 would otherwise prohibit when those transactions involve PDVSA or companies in which the Venezuelan state-owned oil company holds a direct or indirect interest of at least 50%.
OFAC requires contracts with PDVSA or its entities to include dispute-resolution mechanisms in the United States, United Kingdom, France, or Singapore.
Likewise, companies must direct monetary payments intended for blocked persons—except for local taxes, permits, and fees—to the so-called Foreign Government Deposit Funds created under Executive Order 14373, or to another account the U.S. Treasury designates.
Under this framework, U.S. companies can establish commercial relationships with PDVSA despite the sanctions that remain in effect, provided that their operations comply with OFAC’s conditions.
The sanctions behind the license
General License 52C forms part of the broader U.S. sanctions framework on Venezuela.
Executive Order 13850, issued in November 2018, established a framework to block the property of individuals who contributed to certain activities related to the situation in Venezuela and allowed U.S. authorities to target strategic sectors. U.S. authorities later added PDVSA to this sanctions framework. OFAC explains that the order, in its applicable form, provides one of the legal authorities underpinning sanctions against the state-owned oil company.
Executive Order 13884, issued in August 2019, took a broader approach and blocked the property and property interests of the Government of Venezuela.
The license also expressly maintains restrictions stemming from Executive Order 13808, issued in 2017, which limits certain transactions involving debt and securities of the Venezuelan government and PDVSA. In PDVSA’s case, the order prohibits certain transactions involving debt issued after Aug. 25, 2017, with maturities exceeding 90 days.
Meanwhile, Executive Order 13835, issued in May 2018, restricts transactions involving the sale, transfer, assignment, or use as collateral of Venezuelan government equity interests in entities in which the government holds a stake of 50% or more.
The new license, however, does not broadly remove these restrictions. Instead, it specifies that certain transactions involving debt, bonds,s and equity interests remain prohibited.
What OFAC now allows
The most significant change allows a U.S. company that meets the license requirements to conduct transactions with PDVSA and its controlled companies that Executive Orders 13884 and 13850 previously prohibited.
The authorization also covers transactions necessary for the Venezuelan government to participate in those activities, provided that such participation supports authorized transactions and complies with the applicable payment conditions.
In addition, OFAC allows blocked persons who officially serve as officers, employees, or authorized representatives of PDVSA to sign and execute contracts and other documents necessary for authorized operations.
In practical terms, the measure makes it easier for U.S. companies to contract directly with PDVSA, negotiate and execute agreements, and make the corresponding payments through the financial mechanism that Washington established.
The measure adds to other licenses that OFAC has issued this year to enable certain operations by U.S. companies in Venezuela. In March, for example, OFAC explained that General License 52 allowed established U.S. companies to conduct certain activities with PDVSA, including operations involving Venezuelan oil, the supply of diluents, goods, services and technology for oil activities, as well as new investment contracts for exploration, development or production.
In August, the Treasury Department again amended several Venezuela-related licenses and removed, for certain transactions, the requirement that contracts follow U.S. law. However, OFAC maintained the requirement that parties conduct any dispute-resolution proceedings in the United States, United Kingdom, France or Singapore.
The money remains under U.S. control
A central element of the new license is the payment-management mechanism.
Companies cannot simply transfer money owed to a blocked person into a Venezuelan account that allows unrestricted access to the funds. Except for local taxes, permits, and fees, companies must deposit payments into the Foreign Government Deposit Funds or another account that the Treasury Department specifies.
Executive Order 14373, issued in January 2026 and titled “Safeguarding Venezuelan Oil Revenue for the Benefit of the American and Venezuelan People,” established that mechanism.
OFAC has stated that participants depositing into the fund must provide detailed information about the parties, contract, product, volumes, amount, date, and transaction that generated the payment.
The framework therefore allows commercial activity with sanctioned Venezuelan entities while keeping the funds within the U.S. sanctions regime.
Limits to the opening
General License 52C does not broadly lift sanctions against Venezuela or PDVSA.
The authorization excludes transactions involving certain bonds and debt issued by the Venezuelan government or PDVSA, as well as transactions involving the sale, transfer, or use as collateral of Venezuelan government equity interests.
The license also excludes transactions aimed at enforcing liens, judgments, arbitration awards, or other judicial orders that could transfer or affect blocked property.
OFAC also maintains restrictions on other individuals and entities on its Specially Designated Nationals and Blocked Persons (SDN) List, except for the specific exemptions covering PDVSA and its entities.
The license also bars transactions with individuals or entities linked to Russia, Iran, North Korea, or Cuba, as well as certain Venezuelan or U.S. entities controlled by persons subject to Chinese jurisdiction. It also excludes transactions involving blocked vessels.
Another particularly significant restriction for the oil sector prevents companies from using the license to modify the corporate governance structure of PDV Holding, Citgo Holding or CITGO Petroleum Corporation. In other words, the new commercial authorization does not permit changes to Citgo’s corporate control.
Reporting requirements for exports outside the United States
The license also introduces reporting requirements for companies that export, reexport, sell, or supply Venezuelan-origin oil or petrochemical products to countries other than the United States under this authorization.
Companies must provide U.S. authorities with information about the parties involved, products, volumes, amounts, dates, final destinations, and taxes or payments made to the Venezuelan government.
Companies must submit their first report within 10 days of their first transaction and then file additional reports every 90 days for as long as the transactions continue.
The requirement reinforces the closely supervised nature of the opening: Washington allows certain transactions with PDVSA while maintaining mechanisms to trace trade activity and the associated financial flows.
