Michael Volkov delivers the operational compliance program guidance companies must implement to execute safely within OFAC’s new Venezuela general license framework, structured around five program pillars: transaction scoping with mandatory lifecycle revalidation at each critical deal stage; beneficial ownership-based counterparty due diligence that goes beyond standard SDN screening to identify Russia, Iran, Cuba, North Korea, and PRC-connected ownership structures; contract review and modification to incorporate mandatory U.S. governing law provisions, sanctions representations, FGDF payment mechanics clauses, and robust termination rights; pre-built Foreign Government Deposit Fund payment procedures requiring documented legal and compliance approval, a standardized State Department submission package, and advance coordination before payment deadlines arrive; and a transaction-specific reporting compliance program with calendar-tracked deadlines under GL 52, GL 46B, and GL 51B. Michael concludes that the new Venezuela framework creates genuine commercial opportunity but demands purpose-built compliance architecture—companies that proceed without it are not operating within the authorization.