The Office of Foreign Assets Control has issued a series of new general licenses authorizing significant categories of Venezuela-related energy transactions that would otherwise be prohibited under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. These authorizations—General License 46B, General License 51B, General License 52, and General License 50A—represent the most significant expansion of permitted Venezuela-related activity in years. But they are not a relaxation of sanctions. They are highly conditional pathways through a still-operative blocking regime, and companies that treat them as a green light without understanding their operational requirements are taking substantial legal and commercial risk.

This two-part series examines the new general license framework and provides practical compliance guidance for companies evaluating Venezuela-related transactions. Part 1 addresses the legal framework, the scope of the key authorizations, and the critical Foreign Government Deposit Fund payment mechanism. Part 2 will address the operational compliance program companies must build to execute within these authorizations safely.

The Baseline: What the Venezuela Sanctions Regime Actually Does

The Venezuela Sanctions Regulations block all property and interests in property of the Government of Venezuela within the United States or within the possession or control of U.S. persons. Transactions involving blocked persons—or entities owned 50 percent or more by blocked persons—are prohibited absent OFAC authorization. Because PdVSA, Venezuela’s state-owned oil company, and an extensive network of its subsidiaries and affiliated entities fall within this framework, virtually all commercial activity involving Venezuela’s energy sector has historically required either an OFAC license or no U.S. nexus whatsoever.

The new general licenses do not remove this blocking status. PdVSA remains a blocked person. The Government of Venezuela remains a blocked counterparty. What the authorizations do is create defined conditional pathways—subject to mandatory contractual requirements, payment procedures, reporting obligations, and jurisdictional restrictions—through which specified categories of otherwise prohibited activity may lawfully proceed. The framework is an authorization structure, not a sanctions lift. This distinction matters enormously for compliance program design.

General License 52: The Core PdVSA Authorization

General License 52 is the broadest authorization currently available under the Venezuela sanctions program. It permits established U.S. entities—meaning entities organized under U.S. law on or before January 29, 2025—to engage in transactions involving PdVSA and PdVSA-owned entities that would otherwise be prohibited under Executive Orders 13884 and 13850. The authorization extends to transactions involving the Government of Venezuela that are necessary to conduct authorized activities.

The authorization is subject to four critical conditions that define the entire compliance architecture around GL 52:

• U.S. governing law: Any contract with PdVSA, the Government of Venezuela, or PdVSA-owned entities must be governed by the laws of the United States or a U.S. jurisdiction, and dispute resolution must occur in the United States. This is not a recommended contractual provision—it is an express condition of the authorization. Contracts using foreign governing law or non-U.S. arbitration venues cannot rely on GL 52.
• Foreign Government Deposit Fund payments: Monetary payments to blocked Venezuelan governmental counterparties generally cannot be remitted directly to PdVSA or the Government of Venezuela. They must be deposited into the Foreign Government Deposit Fund established under Executive Order 14373, or another account designated by Treasury. This fundamentally changes payment mechanics.
• Jurisdictional restrictions: GL 52 does not authorize transactions involving persons located in, organized under the laws of, or operating through joint ventures with Russia, Iran, Cuba, or North Korea. Transactions involving entities in Venezuela or the U.S. that are owned or controlled by, or operating through joint ventures with, persons from the People’s Republic of China are also excluded.
• Prohibited payment structures: The authorization does not permit debt swaps, in-kind payments, gold payments, commercially unreasonable payment terms, or transactions denominated in Venezuelan digital currencies, including the petro.

General License 46B and GL 51B: Commodity Trading and Minerals Authorizations

General License 46B authorizes a broad range of activities involving Venezuelan-origin oil and petrochemical products, including purchasing, marketing, transportation, storage, delivery, and related commercial activities. Like GL 52, it is available only to established U.S. entities, incorporates the FGDF payment framework, requires U.S. governing law and dispute resolution in contracts with Venezuelan governmental counterparties, and contains the same jurisdictional exclusions for Russia, Iran, Cuba, North Korea, and China-connected entities.

General License 51B, effective June 10, 2026, extends equivalent authorization to Venezuelan-origin minerals, including gold. It authorizes exportation, reexportation, sale, resale, supply, storage, purchase, delivery, and transportation of Venezuelan-origin minerals by established U.S. entities, with the same structural conditions as GL 46B. Critically, GL 51B expressly excludes exploration, development, mining, extraction, and production activities in Venezuela, as well as the formation of joint ventures in Venezuela to engage in those activities. It also prohibits processing or refining of Venezuelan minerals in Russia, Iran, Cuba, North Korea, or China. GL 51B imposes its own reporting obligation: transaction reports are due to [email protected] and [email protected] within ten days of the first transaction and every thirty days thereafter.

The Foreign Government Deposit Fund: The Central Operational Challenge

The FGDF framework established under Executive Order 14373 is the most operationally significant feature of the new Venezuela general license architecture. It solves a fundamental problem: how does a company satisfy payment obligations to a blocked counterparty without transferring funds directly to that party and violating the blocking regime? The FGDF is the answer—but it is not a simple wire transfer. It is a government-mediated payment mechanism with documentary, timing, and procedural requirements that companies must understand before committing to transaction timelines.

The mechanics of the FGDF process work as follows. Companies seeking to make FGDF deposits must contact [email protected] and provide extensive information about the underlying transaction. OFAC guidance indicates that the government may request: the full legal names and addresses of all contract parties including subsidiary information; a detailed description of the underlying contract and the purpose of the payment; product type and quantities; copies of invoices and contract records; the total payment amount, currency, and proposed payment date; identification of the applicable General License; and contact information for follow-up inquiries. Only after this submission process is complete and payment instructions are received can funds be transmitted—and to the designated government account, not to PdVSA directly.

The compliance implications are significant. Companies cannot treat Venezuela-related payments as ordinary commercial wire transfers. Every payment to a blocked Venezuelan governmental counterparty requires pre-payment legal and compliance review, documentation assembly, contact with U.S. government authorities, receipt of payment instructions, and careful verification before transmission. Companies that fail to build FGDF compliance into their transaction planning and payment workflows will face operational disruption—and potentially sanctions exposure.

Reporting Obligations: Not Optional

All three primary general licenses—GL 46B, GL 51B, and GL 52—impose transaction reporting obligations that must be treated as substantive compliance requirements. Under GL 52, any person that exports, reexports, sells, resells, or supplies Venezuelan-origin oil or petrochemical products to destinations outside the United States pursuant to the authorization must file reports to the U.S. Department of State and the U.S. Department of Energy identifying the parties, products, quantities, values, transaction dates, countries of destination, and any taxes, fees, or payments to the Government of Venezuela. Initial reports are due within ten days of the first transaction, with supplemental reports every ninety days while activity continues.

GL 51B imposes a similar reporting regime for minerals transactions, with initial reports due within ten days of the first transaction and subsequent reports every thirty days. The reporting obligations are not administrative niceties. Failure to report required information in a timely and accurate manner is a separate and independent basis for sanctions enforcement action, even where the underlying transaction is fully authorized.

Part 2 of this series will address the operational compliance program structure that companies must build to execute safely within this framework—including transaction scoping, counterparty due diligence, contract structure, FGDF payment procedures, and recordkeeping requirements.