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On January 29, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Venezuela‑related General License 46 (“GL 46”), marking the most significant easing of U.S. restrictions on the Venezuelan oil sector in several years. GL 46 allows “established U.S. entities”—defined as entities organized under U.S. law on or before January 29, 2025—to engage in a broad set of activities involving Venezuelan‑origin oil, subject to certain conditions.

Specifically, GL 46 authorizes “established U.S. entities” to participate in transactions ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, including refining such oil. These authorizations include transactions involving the Government of Venezuela, state-owned oil company Petróleos de Venezuela, S.A. (“PdVSA”), and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest.

Authorized activities include arranging shipping and logistics services, such as chartering vessels, obtaining marine insurance and protection and indemnity (P&I) coverage, and arranging port and terminal services. GL 46 places several important conditions on these activities:

  • Contracts with the Government of Venezuela, PdVSA, or PdVSA Entities must be governed by U.S. law and provide for dispute resolution in the United States;
  • Payments to blocked persons must be deposited into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury; and
  • Companies exporting or supplying Venezuelan-origin oil to non‑U.S. destinations must file detailed reports with the U.S. Departments of State and Energy within 10 days of the first transaction and every 90 days thereafter.

GL 46 does not authorize the following:

  • Payments that are not commercial reasonably or that involve debt swaps, gold, or digital currency or tokens issued by, for, or on behalf of the Government of Venezuela;
  • Transactions involving persons and entities located or organized in Russia, Iran, North Korea, or Cuba.
  • Transactions involving an entity located in or organized in Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized China;
  • The unblocking of any property blocked pursuant to the Venezuela Sanctions Regulations; and
  • Transactions involving a blocked vessel.

Separately, on February 2, 2026, OFAC issued General License 5U (“GL 5U”), which authorizes all transactions related to, the provision of financing for, and other dealings in the PdVSA 2020 8.5% Bond on or after March 20, 2026. GL 5U replaces and supersedes GL 5T, which was issued on December 19, 2025 and would have authorized these transactions beginning on or after February 3, 2026.

Husch Blackwell’s Export Controls and Economic Sanctions Team continues to closely monitor all sanctions and export controls. Should you have any questions or concerns, please contact Cortney Morgan, Grant Leach, Emily Mikes or Eric Dama of our Export Controls and Economic Sanctions Team.