Sanctions Compliance · Venezuela Oil & Investment · 2026

OFAC General License 50A vs GL 52: Who Can Invest in Venezuela Oil?

GL 50A lets six named incumbents keep running live Venezuela oil operations. GL 52 opens the door to new investment for a much wider set of US entities. Here is how the two licenses actually differ — and why OFAC built two separate gates instead of one.

By Caracas Research Published July 27, 2026 9 min read

Key Takeaways

  • GL 50A authorizes six named majors — BP, Chevron, Eni, Repsol, Shell, and Maurel & Prom — to run live oil and gas sector operations with PDVSA today.
  • GL 52, issued March 18, 2026, broadly authorizes new US-person investment in Venezuela's oil sector — the first authorization of its kind since 2019 — without limiting eligibility to a closed list of six companies.
  • Payments to PDVSA under GL 52 must route through US Treasury-controlled Foreign Government Deposit Funds, a materially different payment structure than GL 50A's six incumbents follow.
  • The two licenses solve different problems: GL 50A keeps existing operators running; GL 52 opens a path for new capital that was not already doing business in Venezuela.
  • Neither license authorizes dealing with SDN-listed parties, and transactions involving Russia, China, Iran, North Korea, or Cuba entities remain prohibited regardless of either license.

Anyone evaluating new Venezuela oil-sector activity in 2026 runs into the same question sooner or later: OFAC General License 50A vs GL 52 — which one actually covers what you want to do? Both licenses sit inside the same post-transition wave of Venezuela sanctions amendments and both touch oil-sector transactions with PDVSA. But they answer different questions. GL 50A tells six already-operating majors they can keep working. GL 52 tells a much wider set of established US entities they can put new capital into Venezuela's oil sector for the first time since 2019.

This is not legal advice. Both licenses were issued in the same fast-moving 2026 licensing wave and remain revocable or subject to further amendment. Always verify every provision against the current OFAC text on the Venezuela-Related Sanctions page before you act. When in doubt, seek qualified sanctions counsel.

Side-by-Side Comparison

Here is the quick comparison of OFAC General License 50A vs GL 52 across the dimensions a compliance or deal team cares about most.

DimensionGeneral License 50AGeneral License 52
Who it covers Only BP, Chevron, Eni, Repsol, Shell, and Maurel & Prom, plus their subsidiaries Established US entities more broadly, not limited to a closed list of named companies
Authorized activity Live oil and gas sector operations involving the Government of Venezuela, PDVSA, or PDVSA entities New US-person investment in Venezuela's oil sector, including transactions with PDVSA
New capital vs. existing operations Continuation of pre-existing operating relationships with PDVSA New investment — the first broad authorization of its kind since 2019
Payment channel No special Treasury deposit-fund routing specified Payments to PDVSA must route through US Treasury-controlled Foreign Government Deposit Funds
Reporting duty Must report parties, quantities, and values to the State and Energy Departments within days of the first transaction Payment routing through Treasury-controlled funds; confirm current reporting obligations against OFAC text
Issued Issued as GL 50 on February 13, 2026 (five companies); amended to GL 50A on February 18, 2026, adding Maurel & Prom Issued March 18, 2026
Excluded counterparties SDN-listed parties remain prohibited SDN-listed parties and transactions involving Russia, China, Iran, North Korea, or Cuba entities remain prohibited

Sources: OFAC Venezuela-Related Sanctions program page · OFAC recent action, February 18, 2026 (GL 50A)

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 is oil or gas sector operations conducted by six named companies and their subsidiaries.

Six Named Companies, No Exceptions

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 or its interest in new investment; a seventh company seeking similar authority needs a different vehicle — which is exactly the gap GL 52 fills for new capital. GL 50A requires the six companies to report transaction parties, quantities, and values to the US Departments of State and Energy within days of the first transaction, and it carries no expiration date but remains revocable by OFAC at any time.

For the broader oil-sector licensing landscape these companies also navigate, see our OFAC General License 49A vs GL 50A comparison and our GL 46 vs GL 44A guide.

Sources: OFAC recent action, February 18, 2026 · OFAC recent action, February 13, 2026

What GL 52 Authorizes

General License 52, issued March 18, 2026, broadly authorizes new US-person investment in Venezuela's oil sector, including transactions with PDVSA by established US entities. It is the first authorization of this scope since 2019 — a meaningfully different license from GL 50A because it is not restricted to a closed list of six named companies.

New Capital, Not Just Existing Operators

Where GL 50A lets six incumbents keep operating relationships they already had before Venezuela's political transition, GL 52 is aimed at capital that was not previously doing business in the country. That makes it the license a new entrant — a fund, an independent operator, or a company outside the GL 50A six — would look to first when evaluating fresh Venezuela oil-sector investment.

A Specific Payment Channel

GL 52 imposes a payment-routing condition GL 50A does not: payments to PDVSA must flow through US Treasury-controlled Foreign Government Deposit Funds, rather than moving directly to PDVSA-controlled accounts. This gives Treasury ongoing visibility into how PDVSA-linked proceeds are held and disbursed. Transactions involving Russia, China, Iran, North Korea, or Cuba entities remain prohibited under GL 52 regardless of any other authorization, and dealings with any party on OFAC's Specially Designated Nationals (SDN) list are excluded entirely.

Screening every counterparty before relying on GL 52 is still required. See our Venezuela sanctions checker as a starting point, and our guide to investing in Venezuelan oil for the broader sector context.

Sources: OFAC Venezuela-Related Sanctions

Why Two Different Gates

GL 50A and GL 52 are two pieces of the same larger licensing wave OFAC has issued since Venezuela's political transition in early 2026. 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), and new oil-sector investment (GL 52), among others. See our explainer on why Venezuela is sanctioned for the fuller sanctions history.

Here is the information-gain insight. Read together, GL 50A and GL 52 show OFAC solving two different problems with two different instruments rather than one broad reopening. GL 50A is a continuity license — it keeps six companies that already had PDVSA relationships from having to stop and restart. GL 52 is a new-entrant license — it is the mechanism actually built for fresh capital, and it comes with a payment-routing condition (Treasury-controlled deposit funds) that GL 50A's incumbents were not made to adopt. A company deciding where it fits should ask a narrower question than "can I invest in Venezuela oil" — it should ask whether it already has a pre-transition PDVSA relationship (GL 50A's lane) or is bringing genuinely new capital (GL 52's lane), because the compliance obligations differ meaningfully between the two.

Track this licensing sequence alongside our OFAC Venezuela General Licenses tool, which lists every currently tracked license, and the ongoing Venezuela Sanctions Tracker.

Sources: OFAC Venezuela-Related Sanctions

Choosing the Right License

The threshold question is the same as with any Venezuela oil-sector license: who is the entity, and is this continuity or new capital?

You are looking at GL 50A if…

  • Your entity is BP, Chevron, Eni, Repsol, Shell, or Maurel & Prom (or a named subsidiary).
  • You already had an operating relationship with PDVSA before the 2026 transition.
  • Your activity is continuing live oil or gas sector operations, not new investment.
  • You are prepared to report transaction parties, quantities, and values to State and Energy within days.

You are looking at GL 52 if…

  • You are not one of the six companies named in GL 50A.
  • You are an established US entity bringing new investment into Venezuela's oil sector.
  • You can route any payments to PDVSA through US Treasury-controlled Foreign Government Deposit Funds.
  • You have confirmed no counterparty is SDN-listed or tied to Russia, China, Iran, North Korea, or Cuba.

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.

Frequently Asked Questions

GL 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 is oil or gas sector operations conducted by six named companies -- BP, Chevron, Eni, Repsol, Shell, and Maurel & Prom -- and their subsidiaries. OFAC issued it as GL 50 on February 13, 2026 (five companies) and amended it to GL 50A five days later, adding Maurel & Prom.
GL 52 broadly authorizes new US-person investment in Venezuela's oil sector, including transactions with PDVSA by established US entities. OFAC issued it March 18, 2026 -- the first authorization of its kind since 2019. Unlike GL 50A, it is not limited to a closed list of named companies. Payments to PDVSA under GL 52 must route through US Treasury-controlled Foreign Government Deposit Funds, and transactions involving Russia, China, Iran, North Korea, or Cuba entities remain prohibited regardless of the license.
GL 50A is closed and operational: only six named incumbent majors can rely on it, but for those six, live oil and gas operations with PDVSA are authorized today. GL 52 is open and investment-focused: any qualifying, established US entity can use it to make new investment in Venezuela's oil sector, not just the six GL 50A incumbents -- but payments must flow through the Treasury-controlled deposit-fund mechanism GL 52 specifies.
One of the six GL 50A companies conducting new, additional investment in Venezuela's oil sector -- beyond its existing operations -- could potentially rely on GL 52 for that new-investment activity while continuing to operate existing business under GL 50A. The two licenses are not mutually exclusive; they authorize different kinds of activity. Confirm the specific transaction against the current OFAC text before relying on either license.
Yes. GL 52 requires that payments to PDVSA route through US Treasury-controlled Foreign Government Deposit Funds, rather than moving directly to PDVSA accounts. This channel gives Treasury visibility and control over how PDVSA-linked proceeds are held and disbursed, which is a meaningfully different payment structure than GL 50A imposes on its six named companies.
No. That is the key distinction between the two licenses. GL 50A names exactly six companies -- BP, Chevron, Eni, Repsol, Shell, and Maurel & Prom -- and no other company can rely on it. GL 52 is described in OFAC guidance as available more broadly to established US entities making new investment, without naming a closed list of eligible companies.