What Happened

Following the January 3, 2026 capture of former Venezuelan President Nicolás Maduro by the United States, and significant reforms of Venezuela’s Hydrocarbons Law aimed at opening Venezuela’s oil sector to private sector participation and foreign investment, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued two general licenses to provide sanctions relief for Venezuela's oil sector—General License 46, which authorizes some transactions involving certain Venezuelan-origin oil trade and export-related activities and services by “established US entities,” and General License 47, which authorizes certain transactions relating to the export of U.S.-origin diluents to Venezuela. On February 6, 2026, OFAC issued guidance (in the form of updated FAQs) for US companies seeking to re‑engage with segments of Venezuela’s energy sector. On February 10, 2026, OFAC issued General License 48, further expanding the scope of authorized activities in Venezuela’s energy sector, and issued General License 46A, which superseded and replaced the prior version (but made only nominal changes, as addressed below).

The Bottom Line

The General Licenses and guidance issued by OFAC are part of a rapid recalibration of US sanctions on Venezuela. Companies doing business in or considering doing business in Venezuela’s energy sector should carefully monitor these developments and understand the compliance expectations they create.

The Full Story

Since 2015, the United States has subjected Venezuela’s government to an evolving array of targeted and sectoral sanctions. Since 2019, key blocking sanctions have been in place pursuant to Executive Order (EO) 13884. EO 13884 blocked all property of the government of Venezuela and prohibited US persons from engaging in any transactions directly or indirectly with the government. This prohibition extends to any political subdivision, agency, or instrumentality of the government of Venezuela, including the Central Bank of Venezuela and the state-owned oil company, Petróleos de Venezuela, S.A. (PdVSA), as well as any person or entity owned or controlled, directly or indirectly, by the foregoing and any other person who has acted or purported to act directly or indirectly for or on behalf of, any of the foregoing (including as a member of Nicolás Maduro’s administration). Unless otherwise authorized by OFAC, US persons are generally prohibited from dealing directly or indirectly with any Venezuelan government official or entity.

General License 46 – Venezuelan-Origin Oil

On January 29, 2026, OFAC issued General License (“GL”) 46, authorizing established US companies to engage in a broad range of business activities involving Venezuelan oil, subject to certain conditions and limitations. Under GL 46, “established US entities” (defined as any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025) are authorized to engage in activities that are ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, including the refining of such oil, provided that:

• Any contract for such transactions with the Government of Venezuela, PdVSA (or any person or entity owned or controlled, directly or indirectly, by PdVSA) specify that the laws of the United States or any jurisdiction within the United States govern the contract and that any dispute resolution under the contract occurs in the United States; and
• Any monetary payment to a blocked person is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373, or any other account as instructed by the US Department of the Treasury. (GL 46A narrows that requirement slightly by adding an exception for “payments for local taxes, permits, or fees”; this is the only substantive change imposed by GL 46A).

GL 46 was issued the same day that Venezuela’s acting President, Delcy Eloína Rodríguez Gómez, approved a major reform of Venezuela’s Hydrocarbons Law that aims to reduce taxes, increase independence for private producers, permit asset transfers and outsourcing arrangements, and introduce independent arbitration for disputes in Venezuela’s oil sector—measures that appear intended to encourage foreign investment and private sector participation.

GL 46 represents a significant carve-out from the prior prohibitions of EO 13884 and opens the door for “established US entities” to engage in commercial activities involving Venezuelan oil.  Along with other important limitations, the scope of authorized activity under GL 46 specifically excludes transactions with payment terms that are not commercially reasonable; that involve debt swaps, payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela (including the petro); or that involve certain companies and persons with ties to Iran, North Korea, Cuba, China, or Russia.

GL 46 also requires reporting by persons that export, reexport, sell, resell, or supply Venezuelan-origin oil to countries other than the United States under the license. Such persons must provide a detailed report to the US government that identifies, for each of these transactions: (1) the parties involved; (2) the quantities, values, and countries of ultimate destination; (3) the dates the transactions occurred; and (4) any taxes, fees, or other payments provided to the government of Venezuela. These reports are due 10 days after the execution of the first such transactions and every 90 days thereafter while such transactions are ongoing.

General License 47 – U.S.-Origin Diluents

On February 3, 2026, OFAC issued GL 47, which generally authorizes the export, sale, and supply of U.S.-origin diluents to Venezuela. GL 47 addresses a critical operational need in Venezuela’s oil sector, as diluents are essential for the processing and transport of Venezuelan heavy crude (which is viscous and dense), but the scope of authorized activity is narrow: GL 47 applies only to defined activities, requires adherence to mandatory contract and payment structures, and limits counterparties. GL 47 also has essentially the same restrictions on payment terms and the same reporting requirements as GL 46.

New OFAC Guidance on GL 46

On February 6, 2026, OFAC released new FAQs 1226-1235 that further define how GL 46 operates in practice. While the FAQs do not expand the licenses’ scope, they clarify boundaries, expectations, and the operational mechanics that companies must follow to comply with US sanctions on Venezuela.

The newly published FAQs fall into four thematic categories:

1. Downstream Trading

OFAC confirms that Venezuelan‑origin oil lawfully acquired under GL 46 can be resold, traded, or transported downstream once all blocked interests (including PdVSA) have been fully extinguished. This includes non‑US parties and non‑“established U.S.” entities, so long as the initial transaction complied with GL 46.

Non-US persons may also engage in transactions or provide services that are ordinarily incident and necessary to the established US entity’s transactions authorized by GL 46. Such activities or ancillary services could include: providing transportation and logistics services to an established US entity for the export of Venezuelan-origin oil; providing marine insurance to vessels chartered by established US entities to transport Venezuelan-origin oil; the financing of related cargoes or receivables; leasing storage facilities for Venezuelan-origin oil purchased by an established US entity; or contracting with established US entities for repair or maintenance services of infrastructure necessary to effectuate the export of oil from Venezuela.

2. Verification and Financial Due Diligence

Financial institutions may rely on customer attestations that transactions comply with GL 46, so long as they do not have reason to believe otherwise. OFAC signals that financing channels should remain functional but emphasizes risk‑based monitoring for anomalies.

3. Contracting and Dispute‑Resolution Requirements

The FAQs clarify that mandatory US law and US dispute‑resolution provisions apply only to contracts executed directly between established US entities and the Government of Venezuela or PdVSA. Indirect participants (e.g., insurers, brokers, shippers) generally are not required to adopt these provisions unless they are themselves contracting with blocked parties.

OFAC also explains that to meet the “commercially reasonable” requirement in GL 46, terms must align with market norms for comparable transactions, including quality, quantity, safety, and pricing benchmarks. OFAC expects parties to maintain documentation showing that their terms reflect standard industry practice. Commercially reasonable terms include terms related to, among other things, the governance, economics, operations, and legal/compliance requirements of a contract negotiated at arm’s length between two or more parties.

4. Scope of Authorization

OFAC clarified that GL 46 does not authorize exploration activity or negotiations for new oil sector investments. GL 46 authorizes the purchase, exportation, and sale of Venezuelan-origin oil that has already been extracted, including the refining of such oil. Other exploration or production activities, such as conducting geological surveys, drilling wells, or extracting oil from fields in Venezuela, or activities related to investment in the Venezuelan oil sector, such as negotiations with PdVSA) to enter into a contract to develop or operate oil fields, blocks, or other concessions, remain blocked.

Activities authorized by GL 46 include those that are ordinarily incident and necessary to the lifting (which refers to the physical loading and removal of oil from a terminal, storage facility, or production site for delivery to a buyer), exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil by an established US entity, such as:

• engaging in commercial, legal, and technical discussions necessary to scope purchases of Venezuelan-origin oil, including with third-party legal, commercial, or due diligence consultants;
• conducting safety, environmental, and other relevant inspections, including site surveys;
• arranging logistics, security services, delivery points, and shipping preparation, including obtaining marine insurance and engaging with relevant port or maritime authorities of the Government of Venezuela (GOV) or their personnel;
• conducting certain downstream activities, including the refining and resale of Venezuelan-origin oil;
• coordinating payment structures, including payments in the form of swaps of oil, diluents, or refined petroleum products, among others;
• making required repairs and maintenance to pipeline, storage, or port infrastructure necessary to effectuate the loading of vessels; or
• financing of related cargos or receivables.

The term “Venezuelan-origin oil” as used in GL 46 means crude oil or petroleum products extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products. Crude oil blends such as Merey 16 or bitumen blends, as well as petroleum products or byproducts, including gasoline, asphalt, flexicoke, and petroleum coke, are considered "Venezuelan-origin oil" for the purposes of GL 46.

General License 48 – Services and Supplies for Venezuela’s Energy Sector

On February 10, 2026, OFAC issued GL 48, which generally authorizes transactions that are ordinarily incident and necessary to the provision from the United States or by a US person of goods, technology, software, or services for the exploration, development, or production of oil or gas in Venezuela. Like GL 46 and GL 47, GL 48 applies only to defined activities, requires adherence to mandatory contract and payment structures, and limits counterparties. GL 48 also has essentially the same restrictions on payment terms and the same reporting requirements as GL 46 and GL 47 for any person that exports, reexports, sells, resells, or supplies goods, technology, software, or services pursuant to the license.

Why It Matters

These three General Licenses create new pathways for US companies to re‑engage with segments of Venezuela’s energy sector—but only within a strict, OFAC‑controlled framework. The new FAQs sharpen, rather than loosen, the compliance expectations surrounding these licenses.

At the same time, the rollout reflects an atypical sanctions‑relief sequence: rapid authorizations tied to a historic political transition, coupled with unusually detailed contractual, financial, and reporting safeguards. This blend of accelerated relief and stringent oversight is unprecedented relative to prior sanctions‑easing cycles. Clients should plan for further adjustments as the US government calibrates policy to Venezuela’s evolving political and economic landscape.

Hunton Can Help

If you have questions about US sanctions on Venezuela, these General Licenses, or OFAC’s updated FAQs—or need assistance evaluating whether planned activities fit within the authorized scope—please contact us.