Oil, Minerals, Banking and Bonds — Untangling OFAC’s 2026 Venezuela General Licenses

Introduction

Since the turn of 2026, the Office of Foreign Assets Control has issued or amended Venezuela-related general licenses at a pace unmatched since the original 2019 blocking regime. Over twenty distinct general licenses have been issued, replaced, expanded, or extended in less than six months — oil, gold and natural gas moving under controlled terms, banks transacting with named Venezuelan institutions, and even sovereign debt restructuring getting its first advisory green light in years.

All these changes to the regime do not amount to an overall lifting of the restirctions currently in place against Venezuela. They are precise and demanding carve-outs that authorise narrowly defined activity while leaving the underlying blocking architecture — EO 13884, EO 13850, the SDN designations of the Government of Venezuela (GOV) and PdVSA — fully intact. Every authorization comes with a set of conditions, exclusions, and reporting obligations that determine whether a transaction sits inside the licensed perimeter or outside of it. This also makes compliance with these amendments more challenging.

This article maps that perimeter across four sectors where the licensing activity has been heaviest: oil and petrochemicals, minerals, banking and financial services, and the PdVSA bond authorizations. For each, it sets out what each license permits, the conditions attached, and what remains off-limits — then close with a sector-by-sector compliance summary built specifically around the financial services lens.

Background: From Blocking to Bounded Authorization

Venezuela has been subject to a blocking sanctions regime since Executive Order 13850 (November 2018) and EO 13884 (August 2019), which together designate the Government of Venezuela, PdVSA, and their majority-owned affiliates as blocked persons under the Venezuela Sanctions Regulations (31 CFR Part 591). Absent a license, virtually all dealings with these parties by U.S. persons are prohibited.

The current wave of licensing activity traces back to Executive Order 14373 of January 9, 2026, “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People,” which shielded Venezuelan oil revenue held in U.S. Treasury accounts from judicial process and set the stage for a sequence of general licenses authorizing specific commercial activity. GL 46, issued January 29, 2026, was the opening move — authorizing established U.S. companies to engage in Venezuelan oil trade. Everything that followed through to June 2026 has been an extension, amendment, or sector-specific replication of that initial template.

A recurring structural feature worth flagging up front: most of these licenses are restricted to an “established U.S. entity” — defined consistently across the suite as any entity organized under U.S. law on or before January 29, 2025. This is a deliberate gatekeeping mechanism. New market entrants formed after that date do not qualify, regardless of their U.S. organization.

Oil and Petrochemicals

This is the largest and most actively amended licensing category, and the one most directly tied to the policy objective of restoring Venezuelan crude flows without restarting exploration and production.

GL 46 → 46C — Venezuelan-Origin Oil and Petrochemical Products

GL 46 (January 29, 2026) authorized established U.S. entities to engage in the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil involving the GOV, PdVSA, or PdVSA Entities. GL 46A (February 10) replaced it with refined conditions; GL 46B (March 13) expanded scope to cover Venezuelan-origin petrochemical products imported into the U.S.; and GL 46C (June 10) is the current iteration, easing governing-law and dispute-resolution terms without expanding substantive scope.

Authorised transactions include arranging shipping and logistics, chartering vessels, obtaining marine insurance and P&I coverage, and arranging port and terminal services. Conditions require that contracts specify U.S. (or U.S. state) governing law, and that monetary payments to blocked persons flow into the Foreign Government Deposit Funds established under EO 14373, or another Treasury-instructed account. Notably, the license does not authorize exploration or production activity — only the downstream commercial flow of oil already being produced.

Excluded under GL 46C:

• Payment terms that are not commercially reasonable, debt swaps, gold payments, or settlement in GOV-issued digital currency
• Parties located in or organized under the laws of Russia, Iran, North Korea, or Cuba, and their owned/controlled affiliates
• U.S. and Venezuelan affiliates of Chinese companies, including joint ventures
• Vessels designated as blocked, or 50%+ owned by SDNs
• Unblocking of blocked property

GL 47 → 47A — Sale of U.S.-Origin Diluents to Venezuela

GL 47 (February 3, 2026), now GL 47A (June 10), authorizes the sale of U.S.-origin diluents to Venezuela — a necessary input for processing the country’s predominantly heavy crude. Without diluent supply, Venezuelan heavy oil is largely unmarketable, making this license a practical precondition for GL 46C to function at all.

GL 48A → 48B — Supply of Certain Items and Services to Venezuela

Originally issued as GL 48 alongside the March 2026 oil sector expansion, now GL 48B, this license authorizes transactions related to the maintenance of existing oil or gas operations — including the refurbishment or repair of items used in oil or gas exploration, development, or production activities. The maintenance framing is deliberate: it permits keeping existing infrastructure functional without authorizing new exploration or production investment, which remains the preserve of GL 52A.

GL 50 → 50B — Oil or Gas Sector Operations of Certain Entities

This license authorises all VSR-prohibited transactions involving the GOV, PdVSA, and PdVSA Entities that relate to oil or gas sector operations in Venezuela — but only for entities specifically named in the license’s Annex, and their subsidiaries. This is a named-party authorization rather than a general market opening: counterparties must check the current Annex before relying on GL 50B.

GL 52 → 52A — Transactions Involving PdVSA

GL 52 (March 18, 2026) is the broadest of the oil-sector licenses. It authorises all transactions otherwise prohibited under EO 13884 or EO 13850 involving PdVSA or PdVSA Entities by an established U.S. entity — critically, including the entry into new investment contracts for exploration, development, or production. This effectively superseded the practical need to rely on GL 49A for PdVSA-specific contingent contracts, though GL 52A’s authority is still bounded to PdVSA itself; other GOV-owned industries beyond what other GLs cover (e.g., electricity generation outside the petrochemical scope) remain outside it.

GL 49 → 49A — Contingent Contracts for Investment in Venezuela

GL 49A authorises the negotiation and entry into “contingent contracts” — executory contracts, pro-forma invoices, agreements in principle, bids, or binding memoranda of understanding — involving the GOV, PdVSA, or PdVSA Entities. It does not authorize performance of those contracts; entry into force must be made expressly contingent on a separate, specific OFAC license. In practice, this is a pre-deal negotiation runway, not a deal-closing authorization, and its relevance for PdVSA narrowed considerably once GL 52A’s broader investment authority came into force.

Minerals

The minerals licensing track mirrors the oil sector’s structure almost exactly — product authorization, supply/maintenance authorization, and a contingent-contracts mechanism — applied instead to Venezuela’s gold and broader minerals sector, centered on Minerven (CVG Compañía General de Minería de Venezuela).

GL 51 → 51B — Venezuelan-Origin Minerals, Including Gold

GL 51 (March 6, 2026) authorises transactions involving Venezuelan-origin minerals, including gold, otherwise prohibited under the VSR. GL 51A (March 27) expanded the authorization; GL 51B (June 10) is the current version, amended only for the governing-law and dispute-resolution terms common to the June 10 batch. The same established U.S. entity gatekeeping and prohibited-payment-terms exclusions that apply to GL 46C apply here — no gold payments, no debt swaps, no GOV digital currency settlement.

GL 54 → 54A — Supply of Items and Services for Minerals Operations

The minerals-sector equivalent of GL 48B: authorises the supply of items and services necessary to maintain existing minerals operations, again under a maintenance framing rather than new development authorization.

GL 55 — Contingent Contracts for Investment in Venezuela’s Minerals Sector

Issued alongside GL 51A and GL 54 on March 27, 2026, GL 55 authorises negotiation of and entry into contingent contracts for new investment in Venezuela’s minerals sector — subject to the same constraint as GL 49A: actual performance requires separate, specific OFAC authorisation. Unlike the oil sector, there is no minerals-sector equivalent of GL 52A’s broad investment authority yet, meaning GL 55 remains the operative mechanism for minerals investment negotiation.

Banking and Financial Services

Three licenses, all issued within a tight window between April and May 2026, form the core of the banking and financial services authorisation — and represent the clearest signal yet that the Administration views financial infrastructure, not just commodity flows, as part of its Venezuela engagement strategy.

GL 56 — Commercial-Related Negotiations of Contingent Contracts with the GOV

GL 56 (April 14, 2026) authorises transactions ordinarily incident and necessary to negotiating contingent contracts with the GOV more broadly — extending the contingent-contract mechanism already seen in GL 49A and GL 55 beyond the oil and minerals sectors. As with its predecessors, GL 56 does not authorise entry into or performance of such contracts; that remains contingent on separate OFAC authorisation. Payment terms restrictions mirror the oil and minerals licenses: no debt swaps, no gold payments, no Venezuelan digital-currency-denominated terms.

GL 57 — Financial Services Involving Certain Venezuelan Banks and GOV Individuals

This is the most consequential banking-sector license in the suite. GL 57 authorises financial services transactions involving three named Venezuelan state banks (“Covered Banks”): Banco de Venezuela (BdV), Banco Digital de los Trabajadores (BDdT), and Banco del Tesoro (BdT)— along with any entity 50% or more owned by them, and individuals blocked solely under EO 13884 for acting on behalf of the GOV (provided they are not separately listed as SDNs).

“Financial services” is defined broadly: maintaining and operating accounts, providing banking services, transferring funds, issuing loans, and processing or receiving employment-related payments or benefits. FAQ 1248 clarifies that the reporting obligations attached to GL 57 (and related GLs such as 48A/50A) fall on whichever party is engaged in the licensed “primary authorised activity” — not on every party that touches the transaction chain.

GL 58 — Services in Connection with Potential Debt Restructuring

GL 58 (May 5, 2026) is a new license with no predecessor, and arguably the most forward-looking item in the entire suite. It authorises legal, financial advisory, and consulting services to the GOV, PdVSA, and PdVSA Entities specifically in connection with the assessment, development, or preparation of potential debt restructuring options, proposals, and related materials — covering Venezuela’s roughly $60 billion in defaulted sovereign and PdVSA debt.

Critically, GL 58 does not authorise the restructuring itself, any transfer or settlement of debt, or direct negotiations between the GOV and creditors. It retains the standard exclusion framework (Russia, Iran, North Korea, Cuba, China-affiliated parties) and requires that persons providing services furnish signed service contracts to the Departments of State and Treasury. This is advisory infrastructure, not a restructuring authorisation — a meaningful distinction for any institution weighing involvement.

Bonds

The PdVSA 2020 8.5% bond authorisation has its own distinct licensing track — a chain of sequential general licenses (GL 5T, 5U, 5V, 5W, and now 5X) whose sole function, repeated nearly every time, is to push back the effective date on which dealings in the bond become authorised.

GL 5X — PdVSA 2020 8.5% Bond

Each iteration in this chain authorizes transactions related to, the provision of financing for, and other dealings in the PdVSA 2020 8.5% bond — but only on or after a specified future date, and explicitly not before it. GL 5V (March 19, 2026) set the effective date at May 5, 2026; GL 5W (May 4) pushed it to June 18; and GL 5X (June 18) has pushed it again, to August 4, 2026.

FAQ 595, amended alongside each reissuance, reiterates the practical effect: between October 24, 2019 and the current effective date, there is no authorization in force for transactions that would otherwise require a license under the relevant VSR subsection. For a financial institution holding or transacting in this instrument, the operative fact is simple — the bond authorization is perpetually delayed, not granted, and each new GL number simply confirms the next postponement rather than a substantive change in terms.

Also Issued: Aviation, Diplomatic and Humanitarian Licenses

Several licenses fall outside this article’s core sectors but are worth a brief note:

• GL 30B (Feb 10, 2026) — port and airport operations, ordinarily incident and necessary transactions including aeronautical, customs, and immigration fees.
• GL 24A (Jun 18, 2026) — reissued telecommunications and mail authorization, expanded to cover common-carrier mail and package transactions to, from, or within Venezuela.
• GL 53 (Mar 24, 2026) — official GOV missions to the United States.
• GL 59 (Jun 18, 2026) — Conviasa aircraft safety and airworthiness support, including maintenance, repair, parts supply, and related logistics.
• GL 60 (Jun 25, 2026) — issued in the immediate aftermath of the magnitude 7.2/7.5 earthquakes that struck northwestern Venezuela on June 24, authorizing transactions tied to earthquake relief efforts, including GOV and SDN dealings where ordinarily incident and necessary to the relief effort. In force through October 23, 2026.

The Overall Picture: A Financial Services Summary

None of this amounts to a lifting of Venezuela sanctions. The GOV, PdVSA, and their blocked affiliates remain designated; the licensing architecture is additive, not substitutive. For compliance teams, the practical questions remain:  what specific activity is now inside the licensed perimeter, and what remains categorically outside it.

Oil & Petrochemicals — Permitted / Outside Scope

Permitted: Trading, transporting, insuring, and financing established commercial flows of Venezuelan-origin oil and petrochemicals by established U.S. entities; diluent supply; maintenance and repair of existing oil/gas infrastructure; new PdVSA investment contracts under GL 52A, including exploration and production.

Outside scope: New market entrants formed after January 29, 2025; any dealing with Russian, Iranian, North Korean, Cuban, or Chinese-affiliated counterparties; gold or digital-currency payment terms; transactions with blocked vessels; unblocking of blocked property itself.

Minerals — Permitted / Outside Scope

Permitted: Trading and dealing in Venezuelan-origin minerals including gold; supply and maintenance services for existing minerals operations; negotiation (not performance) of new minerals-sector investment contracts under GL 55.

Outside scope: Actual entry into or performance of new minerals investment contracts without a separate specific license; the same prohibited-party and prohibited-payment-terms exclusions that apply across the oil sector licenses.

Banking & Financial Services — Permitted / Outside Scope

Permitted: Account maintenance, fund transfers, loans, and payment processing involving the three named Covered Banks and their majority-owned entities; employment-related payments to non-SDN GOV-affiliated individuals; advisory, legal, and consulting services to assess and prepare (but not execute) GOV/PdVSA debt restructuring proposals; negotiation of GOV commercial contingent contracts.

Outside scope: Any financial services involving Venezuelan SDNs by name; actual debt restructuring, settlement, or transfer; direct creditor-GOV negotiations; entry into or performance of contingent contracts absent separate specific licensing; dealings with banks not named as Covered Banks under GL 57.

Bonds — Permitted / Outside Scope

Permitted (from August 4, 2026): Transactions related to, financing for, and other dealings in the PdVSA 2020 8.5% bond, once the GL 5X effective date is reached — assuming it is not postponed again.

Outside scope (until then): All such transactions remain unauthorized between October 24, 2019 and the current effective date. Institutions holding this instrument should treat each successive GL number as confirmation of further delay, not a green light, until the date itself arrives without a further postponement.

Taken as a whole, the picture for financial services is conditional, named-party access rather than market normalisation. When relying on this licensing suite, each transaction needs to be verified separately: the established-U.S.-entity status of the parties involved, the absence of any Russia/Iran/North Korea/Cuba/China nexus, commercially reasonable and properly denominated payment terms, and — for anything resembling new investment — whether a separate specific license is required before performance or negotiation process.

Quick-Reference Table- January–June 2026

The table below consolidates every license and amendment referenced in this article, organized by category and current status, for use as a standalone compliance reference.

License	Title	Date Issued	Category	Status
GL 46 → 46A → 46B → 46C	Venezuelan-Origin Oil (and Petrochemical Products)	Jan 29 / Feb 10 / Mar 13 / Jun 10, 2026	Oil & Petrochemicals	Current (46C)
GL 47 → 47A	Sale of U.S.-Origin Diluents to Venezuela	Feb 3 / Jun 10, 2026	Oil & Petrochemicals	Current (47A)
GL 48A → 48B	Supply of Certain Items and Services to Venezuela	Mar 13 / Jun 10, 2026	Oil & Petrochemicals	Current (48B)
GL 50 → 50A → 50B	Oil or Gas Sector Operations of Certain Entities	Feb 13 / Feb 18 / Jun 10, 2026	Oil & Petrochemicals	Current (50B)
GL 52 → 52A	Transactions Involving PdVSA	Mar 18 / Jun 10, 2026	Oil & Petrochemicals	Current (52A)
GL 49 → 49A	Contingent Contracts for Investment in Venezuela (Oil/Gas)	Feb 13 / Mar 13, 2026	Oil & Petrochemicals	Current (49A)
GL 51 → 51A → 51B	Venezuelan-Origin Minerals, Including Gold	Mar 6 / Mar 27 / Jun 10, 2026	Minerals	Current (51B)
GL 54 → 54A	Supply of Items and Services for Minerals Operations	Mar 27 / Jun 10, 2026	Minerals	Current (54A)
GL 55	Contingent Contracts for Investment in Minerals Sector	Mar 27, 2026	Minerals	Current
GL 56	Commercial Contingent-Contract Negotiations with GOV	Apr 14, 2026	Banking & Financial Services	Current
GL 57	Financial Services Involving Named Venezuelan Banks/GOV Individuals	Apr 14, 2026	Banking & Financial Services	Current
GL 58	Advisory Services re: GOV/PdVSA Debt Restructuring	May 5, 2026	Banking & Financial Services	Current
GL 5T  → 5X	PdVSA 2020 8.5% Bond — Effective Date Postponement	Jan / Feb / Mar 19 / May 4 / Jun 18, 2026	Bonds	Current (5X) — effective Aug 4, 2026
GL 24A	Telecommunications and Mail	Jun 18, 2026	Other (mentioned only)	Current
GL 30B	Port and Airport Operations	Feb 10, 2026	Other (mentioned only)	Current
GL 53	Official GOV Missions to the United States	Mar 24, 2026	Other (mentioned only)	Current
GL 59	Conviasa Aircraft Safety and Airworthiness	Jun 18, 2026	Other (mentioned only)	Current
GL 60	Earthquake Relief Efforts	Jun 25, 2026	Other (mentioned only)	Current — expires Oct 23, 2026

Sources

• OFAC, Venezuela-Related Sanctions, ofac.treasury.gov/sanctions-programs-and-country-information/venezuela-related-sanctions
• OFAC Recent Actions: 20260213, 20260202, 20260318, 20260319, 20260327_33, 20260408, 20260414_33, 20260505, 20260625_33 — ofac.treasury.gov/recent-actions
• Federal Register, “Publication of Venezuela Sanctions Regulations Web General Licenses 46, 46A, and 46B,” federalregister.gov
• Mayer Brown, “OFAC Issues New General License Authorizing Established US Companies to Engage in Trade of Venezuelan Oil and Related Activities,” mayerbrown.com
• Greenberg Traurig, “OFAC Issues General Licenses Authorizing Activities Involving the Venezuelan Oil Sector,” gtlaw.com
• Hogan Lovells, “New Green Lights for Venezuela: What Do the Latest U.S. General Licenses Authorize?,” hoganlovells.com
• Baker McKenzie, Global Sanctions and Export Controls Blog: “OFAC Issues Amended and New General Licenses Tied to the Venezuelan Energy Sector”; “OFAC Issues New Venezuela-related General Licenses Authorizing Commercial Negotiations of Contingent Contracts with GOV and Financial Services”; “OFAC Updates Venezuela General Licenses and Issues New Venezuela FAQs”; “OFAC Venezuela Developments: New Conviasa Aircraft General License…”; “OFAC Issues General License for Earthquake Relief Efforts in Venezuela” — sanctionsnews.bakermckenzie.com
• Paul Weiss, “OFAC Issues Coordinated Energy-Related General Licenses for Venezuela, Russia and Iran,” paulweiss.com
• Paul Hastings, “OFAC’s Changes to Venezuela Sanctions Reflect Investment Opportunities, Compliance Risks for US Investors,” paulhastings.com
• U.S. Department of State, “Responding to Venezuela Earthquakes,” state.gov
• U.S. Department of the Treasury, home.treasury.gov

This article is for informational purposes only and does not constitute legal or compliance advice. Always consult a qualified professional.