Key Takeaways
- OFAC General License 46 vs GL 44A are the two currently-relevant Venezuela oil-sector authorizations, but they qualify companies on different tests: GL 46 on entity formation date and ownership; GL 44A on OFAC's own political assessment.
- GL 46 (issued January 29, 2026) authorizes any "established U.S. entity" — organized under U.S. law on or before January 29, 2025, and not owned or controlled by persons from China, Russia, Iran, North Korea, or Cuba — to lift, export, sell, transport, store, and refine Venezuelan-origin oil.
- GL 44A is a broad sector-wide authorization whose issuance and continuation track Venezuela's compliance with Barbados Agreement political milestones — it has a documented history of expiring and being reissued.
- Neither license authorizes new joint ventures, new exploration, or new investment in Venezuela's oil sector.
- Always verify current status of both licenses on OFAC's Venezuela-Related Sanctions page before relying on either for a live transaction.
Contents
Compliance teams evaluating Venezuela oil-sector transactions in 2026 have to sort out OFAC General License 46 vs GL 44A — the two broadest currently-relevant authorizations, and the two most likely to be confused with each other. Both cover oil-sector activity. Both originate from OFAC's Venezuela sanctions program. But they run on entirely different qualification logic: GL 46 asks who you are; GL 44A asks what OFAC currently permits, given the political situation. Getting the distinction right determines whether a transaction is authorized at all.
Side-by-Side Comparison
Here is the quick comparison of OFAC General License 46 vs GL 44A across the dimensions a compliance team checks first.
| Dimension | General License 46 | General License 44A |
|---|---|---|
| Issued | January 29, 2026 | Amended/reissued multiple times since 2023; tied to Barbados Agreement cycle |
| Who qualifies | Any "established U.S. entity" — organized under U.S. law on or before Jan 29, 2025, not owned/controlled by China/Russia/Iran/North Korea/Cuba persons | Any qualifying entity, U.S. or otherwise, when the license is active — not limited by formation date |
| Authorized activities | Lifting, export, sale, transportation, storage, and refining of Venezuelan-origin oil | Oil and gas sector operations broadly — production, lifting, export, and related services |
| Renewal mechanism | Standard general-license administration; not tied to a political trigger | Reissued based on political milestones (Barbados Agreement compliance) — history of lapsing |
| PDVSA payment routing | Must be deposited into Foreign Government Deposit Funds (FGDFs); debt swaps, gold, and Venezuelan digital currency prohibited | No equivalent escrow mechanism specified in the public license text — confirm current payment rules directly with OFAC |
| New JVs / new exploration | Not authorized | Not authorized, even when fully in force |
| Related licenses | GL 47 (diluent exports, Feb 2026), GL 48A (electricity/petrochemicals, Mar 2026) | GL 8M (five-named-company maintenance license) covers a narrower parallel track |
Sources: OFAC Venezuela-Related Sanctions · Caracas Research GL 46 guide and GL 44A vs 8M comparison
What GL 46 Authorizes
General License 46, issued January 29, 2026, opened Venezuelan-origin oil trade to any "established U.S. entity" — a qualification built around formation date and ownership, not company identity or sector experience. To qualify, a U.S. entity must have been organized under U.S. law on or before January 29, 2025 (one year before the license date), and must not be owned or controlled by persons from China, Russia, Iran, North Korea, or Cuba.
Once an entity qualifies, GL 46 authorizes lifting, export, sale, transportation, storage, and refining of Venezuelan-origin oil — a full trade-chain scope, though narrower than "all oil and gas sector operations." Payments owed to the Government of Venezuela or PDVSA must be deposited into Foreign Government Deposit Funds, which the U.S. government controls; debt swaps, gold payments, and Venezuelan digital currency are explicitly prohibited under GL 46.
GL 46 does not authorize new joint ventures in Venezuela. Two follow-on licenses extended its reach: GL 47 (February 3, 2026) authorizes exports of U.S.-origin diluent to Venezuela, and GL 48A (March 13, 2026) extends authorization to the electricity sector (CORPOELEC) and petrochemical products, including fertilizers — but neither authorizes new JV formation either. See our full OFAC GL 46 guide for eligibility detail and the GL 47/48A extensions.
Sources: Caracas Research OFAC GL 46 guide · OFAC Venezuela-Related Sanctions
What GL 44A Authorizes
General License 44A runs on a different logic entirely. Its full title, "Authorizing Certain Transactions Related to Oil or Gas Sector Operations in Venezuela," signals a sector-wide ambition — when it is active, GL 44A does not limit itself to a fixed set of named companies or a formation-date cutoff. Any qualifying entity can engage in oil and gas sector transactions across the value chain: production, lifting, export, and related services.
The catch is the word "when." GL 44A's issuance and continuation are tied directly to Venezuela's compliance with the Barbados Agreement — the late-2023 political framework negotiated between the Maduro government and Venezuelan opposition groups. When Venezuela is seen as meeting its commitments, OFAC has issued or renewed GL 44A. When the political situation deteriorates, GL 44A has expired without renewal. Compliance teams cannot assume the license is active simply because it existed at some point — status must be verified against OFAC's Venezuela page before any transaction relies on it.
Like GL 46, GL 44A does not authorize new exploration, new drilling, or new investment — including new joint ventures — even when fully in force. And transactions with parties on the OFAC SDN list remain prohibited regardless of GL 44A's sector-wide scope. For the narrower five-named-company maintenance track that runs alongside GL 44A, see our GL 44A vs GL 8M comparison.
Sources: Caracas Research GL 44A vs 8M comparison · OFAC Venezuela-Related Sanctions
Which License Applies to You
The threshold question is the same one compliance teams ask for any Venezuela oil-sector license: who is the entity, and what does OFAC currently permit?
You are looking at GL 46 if…
- Your entity was organized under U.S. law on or before January 29, 2025.
- Your entity is not owned or controlled by persons from China, Russia, Iran, North Korea, or Cuba.
- Your activity is trade-related: lifting, export, sale, transport, storage, or refining.
- You are prepared to route PDVSA-owed payments into Foreign Government Deposit Funds.
You are looking at GL 44A if…
- Your entity does not meet GL 46's formation-date or ownership test but needs broader sector-wide activity.
- Your activity involves the fuller oil and gas value chain — production, lifting, export, related services.
- You have verified GL 44A is currently active on OFAC's Venezuela page.
- You have confirmed Venezuela's current Barbados Agreement compliance status.
Both licenses share the same hard limits: no new exploration, no new investment, no new joint ventures, and mandatory SDN screening of every counterparty regardless of which license applies. If your business plan requires a new JV or new field development, no current general license covers it — that requires a specific license from OFAC, granted only in limited circumstances.
Need a documented compliance analysis for a specific counterparty or deal structure? Our team builds tailored sanctions dossiers that map your activity to the current OFAC text. Start with our Venezuela sanctions checker or the full OFAC Venezuela General Licenses tool. For ongoing program developments, see the Venezuela Sanctions Tracker.