Last week Bracewell discussed the Trump administration’s initial easing of restrictions on Venezuelan oil with General License (GL) 46, which opened the door for US companies to revive the long-inaccessible industry. However, GL46 did not fully unlock the sector; it instead authorized limited, albeit important, activities involving Venezuelan oil.

On February 10, 2026, OFAC issued three additional General Licenses related to the Venezuelan oil sector. Of note, the GLs permit, subject to restrictions, certain activities related to exploration and development, and transactions with the Venezuelan maritime authority, Instituto Nacional de los Espacios Acuáticos (INEA). OFAC has also issued numerous FAQs to provide clarity on these authorizations, including regarding the involvement of non-US Entities as defined in GL46.

Below we highlight key elements of this new authority and guidance. Together, these actions build on GL46 and demonstrate the administration’s gradual approach to reopening the industry, balancing the desire to exploit these resources with the desire to protect the American companies that do so.

This is certain to be a dynamic area of opportunity and risk, and there will no doubt be additional GLs and FAQs as the administration evaluates the implementation of the measures taken thus far. Bracewell’s government enforcement and investigations team is keeping on top of developments and ready to provide tailored guidance.

  • GL 46A, Authorizing Certain Activities Involving Venezuelan-Origin Oil, amends GL 46 by creating a carve out to allow payments to blocked entities for local taxes, permits, or fees.
  • GL 48, Authorizing the Supply of Certain Items and Services to Venezuela, permits all transactions that are ordinarily incident to the provision from the US or by a US person of goods, technology, software, or services for the exploration, development, or production of oil or gas, including to Petróleos de Venezuela S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, PdVSA Entities), subject to conditions and restrictions similar to those of GL46.
    • Examples of Authorized Transactions: GL 48 authorizes processing payments; arranging shipping and logistics services, including chartering vessels; obtaining marine insurance and protection and indemnity coverage; arranging port and terminal services, including with port authorities or terminal operators that are part of the Government of Venezuela; transactions for the maintenance of oil or gas operations, including the refurbishment or repair of items used for oil or gas exploration, development, or production activities.
    • Requirements: To comply with GL 48:
      • Any contract with the Government of Venezuela, PdVSA, or PdVSA Entities must specify that it is governed by US law and any dispute resolution under the contract take place in the US.
      • Any monetary payment to a blocked person (such as a PdVSA Entity), excluding payments for local taxes, permits, or fees, must be made into the Foreign Government Deposits Fund (FGDF).
    • Restrictions: GL 48 does not authorize:
      • Payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro.
      • Any transaction involving a person located in or organized under the laws of Russia, Iran, North Korea, Cuba, or China.
      • The unblocking of any blocked property.
      • The formation of new joint ventures or other entities in Venezuela to explore or produce oil or gas.
      • Any transactions or dealings related to the exportation or reexportation of diluents to Venezuela.
  • GL 30B, Authorizing Certain Transactions Necessary to Port and Airport Operations, permits all transactions and activities involving the Government of Venezuela and the INEA and its 50 percent-or-more owned subsidiaries, that were formerly prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (VSR) and are ordinarily incident and necessary to operations or use of the country’s ports and airports.

OFAC has also issued numerous FAQs providing additional clarification on the GLs.

  • FAQ 1233 explains that the dispute resolution requirement in paragraph (a)(1) of GL 46, requiring jurisdiction in the US, applies only to contracts governing transactions undertaken by an established US entity when the contract is with the Government of Venezuela or PdVSA Entities. It does not apply to indirect parties or indirect counterparties involved in transactions authorized by GL 46, such as downstream transactions involving the provision of shipping, insurance, or other services to an entity engaged in a transaction involving PdVSA. For example, this provision would not apply to a contract between an insurance provider and an established US entity engaged in a transaction with PdVSA to purchase Venezuelan-origin oil (though it would apply to the contract between the US entity and PdVSA).
  • FAQ 1235 explains that GL 46 authorizes downstream trading activities in Venezuelan oil: once a transaction with the Government of Venezuela or PdVSA Entities has been completed pursuant to GL 46, and the interest — including any future or contingent interest — of a blocked entity is fully extinguished, then the oil can be freely sold, resold, and traded by any downstream purchaser, including entities that are not established US entities.
  • FAQ 1230 explains that non-US persons or entities may engage in transactions or provide services that are ordinarily incident and necessary to the established US entity’s transactions authorized by GL 46. Such activities or ancillary services could include: providing transportation and logistics services to an established US entity for the export of Venezuelan-origin oil; providing marine insurance to vessels chartered by established US entities to transport Venezuelan-origin oil; the financing of related cargoes or receivables; leasing storage facilities for Venezuelan-origin oil purchased by an established US entity; or contracting with established US entities for repair or maintenance services of infrastructure necessary to effectuate the export of oil from Venezuela, among others.
  • FAQ 1234 provides that, in connection with its normal due diligence, a financial institution may rely on the statements of its customer that the transaction is consistent with the terms of GL 46, unless it knows or has reason to know otherwise.
  • FAQ 1232 defines “commercially reasonable terms” as those “that are consistent with prevailing market and industry standards for like or similar products produced by a company of similar size and scope, while taking into account characteristics such as quality, quantity, pricing, performance, and safety, among others. Commercially reasonable terms include terms related to, among other things, the governance, economics, operations, and legal/compliance requirements of a contract negotiated at arm’s length between two or more parties.”
  • FAQ 1227 provides a more robust list of activities that are permitted and prohibited by the GLs.