On March 18, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Venezuela General License 52 (GL 52), authorizing established U.S. entities to engage in a broad range of transactions involving Petróleos de Venezuela, S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest. OFAC simultaneously issued FAQ 1245 and FAQ 1246, and amended four prior general licenses — 46B, 48A, 49A, and 50A — extending or refining authorizations across Venezuelan-origin oil, petrochemicals, and electricity sector activities.
GL 52 is the broadest PdVSA-related authorization OFAC has issued under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. It does not lift sanctions. PdVSA, PdVSA Entities, and the Government of Venezuela remain blocked under Executive Order 13850 and Executive Order 13884. GL 52 establishes a structured pathway for permitted activity, conditioned on counterparty restrictions, choice-of-law requirements, and a regimented payment-routing mechanism into the Foreign Government Deposit Funds account established by Executive Order 14373. The license complements the firm's federal regulatory practice and is directly relevant to companies served through the firm's outside general counsel engagements in regulated industries.
GL 52 authorizes transactions otherwise prohibited by Executive Orders 13884 and 13850 involving PdVSA and PdVSA Entities, when conducted by an established U.S. entity. Authorized activity includes the lifting, exportation, sale, supply, marketing, and transportation of Venezuelan-origin oil and petroleum products; the provision to Venezuela of diluent, goods, services, and technologies for exploration, development, or production in the oil, gas, and petrochemical sectors; the entry into new investment contracts; the formation of new joint ventures or other entities in Venezuela tied to such activities; and all transactions ordinarily incident and necessary to those activities, including commercial, legal, technical, safety, and environmental due diligence.
OFAC defines an established U.S. entity as any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025. Non-U.S. subsidiaries of U.S. parents are not directly authorized.
Two contractual conditions apply to every transaction conducted in reliance on GL 52. The contract must be governed by U.S. law, and any dispute resolution must occur in the United States. Any payment to a blocked person — including PdVSA or any PdVSA Entity — must be deposited into the Foreign Government Deposit Funds account or another account designated by Treasury, with the limited exception of payments for local taxes, permits, or fees.
GL 52 does not authorize transactions involving bonds or other debt of the Government of Venezuela or PdVSA, nor transactions involving the sale, transfer, assignment, or pledge of any equity interest in PdVSA Entities, including PDV Holding, CITGO Holding, and CITGO Petroleum Corporation. FAQ 1246 confirms that GL 52 does not authorize the sale of CITGO shares at issue in Crystallex International Corporation v. Bolivarian Republic of Venezuela; a specific license remains required.
The license also excludes transactions with persons on OFAC's Specially Designated Nationals and Blocked Persons List (other than PdVSA Entities themselves), transactions involving counterparties located in or organized under the laws of Russia, Iran, North Korea, or Cuba, and transactions involving entities owned or controlled by, or in joint venture with, persons in the People's Republic of China. Payment terms that are not commercially reasonable, payment in digital currency or tokens issued by or for the Government of Venezuela, debt swaps, and in-kind payments are all outside the authorization. The unblocking of property and any transaction involving a blocked vessel remain prohibited.
Parties relying on GL 52 to export, reexport, sell, resell, or supply Venezuelan-origin oil or petrochemical products to countries other than the United States must report transaction details to the U.S. Departments of State and Energy ten days after execution of the first transaction, and every ninety days thereafter for ongoing transactions. Reporting must include parties involved, product description, quantities, values, transaction dates, ultimate destination countries, and any taxes, fees, or other payments to the Government of Venezuela.
GL 46B replaces GL 46A and extends the authorization for Venezuelan-origin oil to specified petrochemical products, fertilizers, and fertilizer precursor chemicals enumerated in a new annex. GL 48A extends the authorization beyond oil and gas to include exploration, development, or production of certain petrochemical products, and to electricity generation, transmission, storage, and distribution in Venezuela. GL 49A extends contingent-contract authorization to petrochemical and electricity activity. GL 50A adds a sixth named operator — a French company — to the list of foreign operators authorized to conduct oil or gas operations in Venezuela.
GL 52 is structured, not expansive. The choice-of-law condition, the payment-routing mechanism, and the counterparty exclusions impose contractual architecture that must be embedded in any commercial structure from inception, not bolted on at execution. Companies that align contracts, payment flows, and diligence to OFAC's parameters before pursuing a Venezuelan engagement will operate within the authorization. Companies that proceed without that architecture risk acting outside the license — and under a sanctions regime that remains otherwise comprehensive. Counsel coordinating cross-border regulatory exposure, federal government affairs, and contract architecture will need to integrate sanctions compliance into the broader transaction structure from the outset.
GL 52 contains no expiration date but remains subject to revocation by OFAC at any time. It does not relieve any party of compliance with the Export Administration Regulations administered by the Bureau of Industry and Security, the Foreign Corrupt Practices Act, the False Claims Act, or any other federal compliance regime. Since March 18, 2026, OFAC has issued additional Venezuela-related general licenses — GLs 53 through 57 — addressing official missions, minerals, contingent contracts, and financial services. None modifies GL 52 directly, but the Venezuela authorization framework continues to evolve.
Maceira Zayas shall continue monitoring developments and shall publish legal updates on significant changes. Please contact any of the author for further guidance.
