Key Takeaways
- GL 50A authorizes six named majors — BP, Chevron, Eni, Repsol, Shell, and Maurel & Prom — to run live oil and gas sector operations in Venezuela right now.
- GL 49A authorizes any qualifying U.S. person to negotiate and sign a contingent investment contract for oil, gas, petrochemical, or electricity projects — but performance must be expressly contingent on a separate, future OFAC authorization that has not yet been granted.
- Both licenses are recent amendments in the same wave: GL 50 issued February 13, 2026 (five companies), amended to GL 50A on February 18, 2026 (adding Maurel & Prom); GL 49 issued earlier, superseded by GL 49A on March 13, 2026 (adding petrochemicals and electricity).
- The practical gap is two-tier: incumbents named in GL 50A operate now with no further sign-off per deal; anyone using GL 49A can paper a deal now but must wait on OFAC before a dollar moves.
- Neither license authorizes dealing with parties on the OFAC SDN list, and GL 50A carries an active reporting duty to the U.S. Departments of State and Energy.
Contents
Investors and compliance teams evaluating new Venezuela oil-sector activity in 2026 keep running into the same question: OFAC General License 49A vs GL 50A — which one actually applies? Both licenses sit inside the same Feb–Mar 2026 wave of Venezuela sanctions amendments, and both touch the oil and gas sector. But they solve different problems for different audiences. GL 50A is an operating license for six companies that were already doing business in Venezuela. GL 49A is a negotiating license for everyone else — a way to get a deal on paper while OFAC decides whether it can actually close.
Side-by-Side Comparison
Here is the quick comparison of OFAC General License 49A vs GL 50A across the dimensions a compliance or deal team cares about most.
| Dimension | General License 49A | General License 50A |
|---|---|---|
| Who it covers | Any qualifying U.S. person or entity, open-ended | Only BP, Chevron, Eni, Repsol, Shell, and Maurel & Prom, plus their subsidiaries |
| Authorized activity | Negotiating and entering contingent contracts for new investment in oil, gas, petrochemical, or electricity projects | Live oil and gas sector operations involving the Government of Venezuela, PDVSA, or PDVSA entities |
| Can you actually move money today? | No — performance must be expressly contingent on a separate future OFAC authorization | Yes — operations are authorized now, no per-deal sign-off required |
| Reporting duty | Contract must state the OFAC contingency on its face; no separate transaction reporting | Must report parties, quantities, and values to the State and Energy Departments within days of the first transaction |
| Issued / amended | Superseded GL 49 on March 13, 2026, adding petrochemicals and electricity | Issued as GL 50 on February 13, 2026 (five companies); amended to GL 50A on February 18, 2026, adding Maurel & Prom |
| Expiration | No expiration date; revocable by OFAC at any time | No expiration date; revocable by OFAC at any time |
Sources: OFAC recent action, March 13, 2026 (GL 48A/49A) · OFAC recent action, February 18, 2026 (GL 50A)
What GL 49A Authorizes
General License 49A authorizes negotiations of, and entry into, contingent contracts for certain investment in Venezuela. OFAC issued it on March 13, 2026, replacing the earlier GL 49 and widening its scope beyond oil and gas to also cover petrochemical products and electricity-sector operations.
The operative word is contingent. GL 49A defines "contingent contracts" broadly — executory contracts, executory pro forma invoices, agreements in principle, executory offers, and similar instruments all qualify. What every one of those instruments must share is an express condition: performance is contingent on OFAC granting a separate, future authorization. That contingency has to appear in the contract's own text. An implied or assumed contingency — the parties simply understanding that a license will be needed later — is not legally sufficient under GL 49A.
What GL 49A Does Not Let You Do
GL 49A does not authorize actually performing the underlying deal. A company can use it to line up a Venezuelan electricity-generation joint venture, negotiate terms, and sign paperwork — but cannot deliver equipment, transfer funds, or begin operations until a further OFAC license specifically authorizes performance. That makes GL 49A a queueing mechanism as much as an authorization: it lets capital position itself for Venezuela without OFAC having to pre-clear the deal's substance up front.
Transactions with any party on OFAC's Specially Designated Nationals (SDN) list remain prohibited regardless of GL 49A. Screening every counterparty — including PDVSA subsidiaries and state-linked joint-venture partners — is still required before any contingent contract is signed. See our Venezuela sanctions checker as a starting point.
Sources: OFAC recent action, March 13, 2026 · OFAC Venezuela-Related Sanctions
What GL 50A Authorizes
General License 50A authorizes transactions otherwise prohibited under the Venezuela Sanctions Regulations that involve the Government of Venezuela, PDVSA, or PDVSA entities, so long as the activity relates to oil or gas sector operations in Venezuela conducted by six named companies and their subsidiaries.
Six Named Companies
OFAC issued the license as GL 50 on February 13, 2026, naming five companies: BP, Chevron, Eni, Repsol, and Shell. Five days later, on February 18, 2026, OFAC added a sixth — Maurel & Prom — and reissued the license as GL 50A. No other company can rely on GL 50A, regardless of its prior Venezuela experience; a seventh major seeking the same authorization would need its own specific OFAC license.
An Active Reporting Duty
GL 50A is not a silent authorization. It requires the six companies to report transaction details — the parties involved, quantities, and values — to the U.S. Department of State and the U.S. Department of Energy within days of the first transaction under the license. GL 50A carries no expiration date, but OFAC can revoke it at any time, and it does not relieve any company of separate obligations to other federal agencies, including export-control requirements enforced by the Commerce Department's Bureau of Industry and Security (BIS).
For the broader oil-sector licensing landscape these companies also navigate, see our OFAC General License 41 vs 46 comparison and our GL 44A vs GL 8M guide.
Sources: OFAC recent action, February 18, 2026 · OFAC recent action, February 13, 2026
Why Two Licenses Now
GL 49A and GL 50A are not isolated releases — they are two pieces of a much larger licensing wave OFAC has issued since Venezuela's political situation shifted in early 2026, following the removal of Nicolás Maduro from power and the installation of a transitional government. In that window, OFAC issued or amended more than half a dozen Venezuela general licenses covering diluent sales (GL 47), agricultural and petrochemical supply (GL 48A), contingent investment (GL 49A), active oil operations (GL 50A), minerals including gold (GL 51A), and PDVSA-specific transactions (GL 52), among others. See our explainer on why Venezuela is sanctioned for the fuller sanctions history.
Here is the information-gain insight. Read side by side, GL 49A and GL 50A reveal that OFAC is not simply "opening" Venezuela's oil sector — it is sequencing who gets to move first. The six GL 50A companies already had operating relationships with PDVSA before the transition, so OFAC let them keep running with only a reporting duty attached. Everyone else — new capital, new operators, new joint-venture partners — is routed through GL 49A's contingent-contract holding pattern: paper the deal now, but wait for OFAC to decide, deal by deal, whether it can actually close. That is a deliberate two-tier gate, not an oversight, and it means new entrants should expect a second licensing step that the six incumbents were never required to clear.
Track this licensing sequence alongside our guide to investing in Venezuelan oil and the full OFAC Venezuela General Licenses tool, which lists every currently tracked license.
Sources: OFAC Venezuela-Related Sanctions · OFAC recent action, March 13, 2026
Choosing the Right License
The threshold question is the same as with any Venezuela oil-sector license: who is the entity, and what are they actually trying to do?
You are looking at GL 49A if…
- You are not one of the six companies named in GL 50A.
- You want to negotiate or sign a new investment deal in oil, gas, petrochemicals, or electricity.
- You accept that performance depends on a separate OFAC authorization you do not yet have.
- Your contract expressly states the OFAC contingency, not just an implied understanding.
- You have screened all counterparties against the current SDN list.
You are looking at GL 50A if…
- Your entity is BP, Chevron, Eni, Repsol, Shell, or Maurel & Prom (or a named subsidiary).
- Your activity is live oil or gas sector operations in Venezuela, not a new investment negotiation.
- You are prepared to report transaction parties, quantities, and values to State and Energy within days.
- You have confirmed the license has not been revoked or narrowed since your last review.
- You have separately confirmed compliance with BIS export-control requirements.
Both licenses share the same hard floor: neither authorizes transactions with SDN-listed parties, and neither is a substitute for a documented, deal-specific compliance review. Need a tailored read on a specific counterparty or transaction? Our team builds sanctions dossiers mapped to the current OFAC text. Start with our Venezuela sanctions checker or the OFAC Venezuela General Licenses tool for the full license inventory, and follow ongoing developments on the Venezuela Sanctions Tracker.