Key Takeaways
- OFAC General License 41 vs 46 are different eras: GL 41 (2022) was Chevron-specific; GL 46 (2026) is a broader oil-trade framework.
- GL 41 is no longer active. OFAC amended it to a wind-down (GL 41A) and the window closed at 12:01 a.m. EDT on April 3, 2025.
- GL 46 is the current license. It was issued January 29, 2026, then amended by GL 46A and GL 46B.
- GL 46 covers "established U.S. entities" — those organized under U.S. law on or before January 29, 2025 — not just one company.
- Neither license authorizes new exploration or new oil-sector investment, and payments tied to PdVSA face strict controls.
Contents
Compliance officers often ask about OFAC General License 41 vs 46 in the same breath. Both touch Venezuela's oil sector. Both come from the U.S. Treasury's Office of Foreign Assets Control (OFAC). But they belong to different policy moments and authorize very different things. This guide breaks down the scope, dates, and limits of each, so you can map your activity to the right authorization.
Side-by-Side Comparison
Here is the quick comparison of OFAC General License 41 vs 46 across the dimensions a compliance team cares about most.
| Dimension | General License 41 | General License 46 |
|---|---|---|
| Who it covers | Chevron Corporation and its joint ventures with PdVSA | "Established U.S. entities" organized under U.S. law on or before Jan 29, 2025 |
| What it authorized | Production, lifting, sale, export, and import of petroleum from Chevron's Venezuela joint ventures | Transactions ordinarily incident to lifting, export, sale, transport, storage, and refining of Venezuelan-origin oil |
| Issue date | November 26, 2022 | January 29, 2026 |
| Amendments | GL 41A (wind-down, early March 2025) | GL 46A (Feb 10, 2026); GL 46B (Mar 13, 2026) |
| Wind-down vs ongoing | Wind-down only; authorization expired April 3, 2025 | Ongoing; no fixed expiration date stated, but revocable anytime |
| New investment / exploration | Not authorized | Not authorized |
| Current status (2026) | Inactive — superseded and expired | Active (as GL 46B), subject to ongoing OFAC updates |
Sources: Holland & Knight on GL 41/41A · Greenberg Traurig on GL 46/46A · OFAC Venezuela-Related Sanctions
What General License 41 Authorized
OFAC issued General License 41 on November 26, 2022. It was narrow by design. The license let Chevron Corporation resume limited operations through its joint ventures with Petróleos de Venezuela, S.A. (PdVSA).
In plain terms, GL 41 covered the production, lifting, sale, export, and import into the U.S. of petroleum from those Chevron joint ventures. It did not open the door to other dealings with PdVSA. It also did not let PdVSA receive cash profits from the oil sales.
The picture changed in 2025. The administration reversed course, and OFAC amended GL 41 into a wind-down license (GL 41A). That wind-down window closed at 12:01 a.m. EDT on April 3, 2025. After that date, the GL 41 authorization no longer applied.
So when compliance teams weigh OFAC General License 41 vs 46 today, the key fact is simple. GL 41 is history. You cannot rely on it for activity in 2026.
Sources: Holland & Knight · Federal Register: GL 41A, 5R, 41B
What General License 46 Authorizes
General License 46 is the current framework. OFAC issued it on January 29, 2026. It is broader than GL 41 because it does not name a single company.
GL 46 covers "established U.S. entities." OFAC defines these as entities organized under U.S. law on or before January 29, 2025. New shell entities formed to chase the opening do not qualify.
The license authorizes transactions ordinarily incident and necessary to oil trade. That includes lifting, export, sale, resale, supply, storage, transport, and refining of Venezuelan-origin oil. Later updates clarified that this reaches crude, blends, and petroleum products, plus related shipping, insurance, and port services.
OFAC then amended GL 46 twice. GL 46A arrived February 10, 2026. GL 46B followed on March 13, 2026. Each version refined the scope and conditions, so always check the latest text.
One limit stays constant. GL 46 does not authorize oil exploration, new oil-sector investment, or the formation of new joint ventures. It also excludes broader gas and energy activity. For the full breakdown, see our OFAC General License 46 guide and the master list in our OFAC general licenses tool.
Sources: Greenberg Traurig · Crowell & Moring
Payments, PdVSA, and Restrictions
Payments are where many compliance reviews fail. Both licenses guard the cash flow to PdVSA, but in different ways.
| Restriction | General License 41 | General License 46 |
|---|---|---|
| Cash to PdVSA | Blocked PdVSA from receiving profits from the oil sales | Payments must go to Foreign Government Deposit Funds (except local taxes, permits, fees), kept under U.S. control |
| Payment form limits | Tied to the Chevron JV structure; no other PdVSA dealings | No debt swaps, no gold, no Venezuelan digital currency; payments must be commercially reasonable |
| Third-country risk | Activity limited to Chevron JVs only | Excludes dealings tied to Russia, Iran, North Korea, Cuba, or China |
| Scope of activity | Petroleum from Chevron JVs only | Oil trade by any qualifying established U.S. entity |
If your payment routes outside Foreign Government Deposit Funds, or uses a barred payment form, GL 46 will not protect it. Before you screen counterparties, run them through our Venezuela sanctions checker. For background on why these controls exist, read why Venezuela is sanctioned.
The Verdict: Which License Applies
For nearly every situation in 2026, the answer is GL 46, not GL 41. Here is the quick test.
You're looking at GL 41 if…
- You are reviewing historical activity from 2022 to early 2025.
- The transaction involved Chevron's PdVSA joint ventures.
- You need to confirm a past wind-down ended by April 3, 2025.
- You should treat GL 41 as expired for any current dealing.
You're looking at GL 46 if…
- Your entity was organized under U.S. law on or before Jan 29, 2025.
- You trade, ship, store, or refine Venezuelan-origin oil.
- You can route payments through Foreign Government Deposit Funds.
- You are not seeking new exploration or new investment.
Both licenses share a hard limit: they do not green-light new exploration or new oil-sector investment. If your plan needs either, no current general license covers it, and you should seek counsel or a specific license.
Need a documented compliance read for a specific deal or counterparty? Our team builds tailored sanctions dossiers that map your activity to the current OFAC text. You can also start free with our Venezuela sanctions checker.
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