Key Takeaways
- GL 46 authorizes certain Venezuela oil transactions for eligible parties OFAC · as of 2026-01-29 · last verified
- Eligibility: Must be organized under U.S. law on or before January 29, 2025, and not owned/controlled by Chinese, Russian, Iranian, North Korean, or Cuban persons
- All payments to Venezuela/PDVSA must go into Foreign Government Deposit Funds controlled by the U.S. government
- Contracts must be governed by U.S. law with dispute resolution in the United States
- Followed by GL 47 (diluent exports, Feb 3) and GL 48A (electricity/petrochemicals, Mar 13)
Contents
What Is General License 46?
General License 46, titled "Authorizing Certain Activities Involving Venezuelan-Origin Oil," was issued by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on January 29, 2026. It authorizes transactions that were previously prohibited under the Venezuela sanctions program (Executive Order 13850 and related orders).
The license was issued on the same day Venezuela's National Assembly approved the Hydrocarbons Law Reform, signaling coordinated U.S.-Venezuelan policy alignment on reopening the oil sector.
Scope of Authorized Activities
GL 46 authorizes established U.S. entities to engage in transactions that are "ordinarily incident and necessary" to the following activities involving Venezuelan-origin oil:
- Lifting and extraction of crude oil
- Exportation and re-exportation of Venezuelan-origin crude
- Sale and purchase of Venezuelan crude and petroleum products
- Transportation and storage
- Refining of Venezuelan-origin crude
- Arranging shipping and logistics services
- Chartering vessels for oil transport
- Obtaining marine insurance
- Arranging port and terminal services
Source: Morgan Lewis (Feb 2026)
Eligibility Requirements
Not every U.S. company qualifies. GL 46 defines an "established U.S. entity" with specific requirements:
- Must be organized under the laws of the United States on or before January 29, 2025 (one year before the license date)
- Cannot be owned or controlled by persons from China, Russia, Iran, North Korea, or Cuba
- Must be engaged in lawful commercial activities in the United States
Compliance note: The January 29, 2025 cutoff date means newly formed SPVs or shell companies created specifically to exploit GL 46 are ineligible. OFAC designed this to limit the license to established market participants.
Source: Sullivan & Cromwell
Payment Conditions & Fund Controls
GL 46 imposes strict payment controls to prevent Venezuelan government misuse of oil revenues:
- All payments to the Government of Venezuela or PDVSA must be deposited into Foreign Government Deposit Funds
- The U.S. government retains control over these funds
- Payment terms must be "commercially reasonable"
- Prohibited payment methods: debt swaps, gold payments, Venezuelan state digital currency
Contracts with Venezuelan entities must be governed by U.S. law with dispute resolution in the United States — providing legal certainty absent in Venezuela's domestic courts.
Source: Morgan Lewis
Reporting Requirements
Entities exporting or reselling Venezuelan oil to countries other than the United States must report transactions to both the U.S. Department of State and the Department of Energy. Required details include:
- All parties involved in the transaction
- Quantities and grade of crude
- Transaction values
- Final destinations
- Dates of lifting, shipping, and delivery
- Any payments made to the Venezuelan government or PDVSA
Source: Foley Hoag (Feb 2026)
What You Can and Cannot Do
Authorized Under GL 46
- Purchase and import Venezuelan crude to the U.S.
- Export Venezuelan crude to third countries (with reporting)
- Charter vessels and obtain marine insurance
- Arrange port/terminal services
- Refine Venezuelan crude in U.S. facilities
- Contract with PDVSA under U.S.-law-governed agreements
Still Prohibited
- Transactions with persons from China, Russia, Iran, North Korea, Cuba
- Forming new joint ventures in Venezuela
- Debt swaps or payments in gold/digital currency
- Activities by entities formed after January 29, 2025
- Transactions with SDN-listed individuals or entities (unless specifically licensed)
- Non-oil sector activities (see GL 48A for electricity/petrochemicals)
Subsequent Licenses: GL 47 & GL 48A
General License 47 — U.S.-Origin Diluent Exports
Authorizes exports of U.S.-origin diluent (naphtha and other light hydrocarbons) to Venezuela, critical for blending with Venezuela's heavy Orinoco Belt crude to make it pipeline-transportable and exportable.
General License 48A — Electricity & Petrochemicals
Expanded authorized activities to include Venezuela's electricity sector — generation, transmission, storage, and distribution. CORPOELEC (state electricity monopoly) is now an authorized counterparty. Also covers petrochemical products and fertilizers.
For real-time tracking of all Venezuela-related OFAC actions, see our OFAC Sanctions Tracker and General Licenses Directory.
Sources: Holland & Knight · Baker McKenzie · Cleary Gottlieb