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OFAC Clears Limited Venezuelan Oil Transactions Under Strict Conditions

The authorization requires U.S.-law contracts with Treasury-held payments, keeping upstream development off-limits.

Overview

  • General License 46 permits established U.S. entities to conduct lifting, transport, sale, storage, marketing, delivery, and refining of Venezuelan-origin oil, including dealings with the Government of Venezuela and PdVSA.
  • Eligibility is limited to entities organized in the United States on or before January 29, 2025, excluding non‑U.S. firms and newly formed U.S. companies.
  • Payments owed to blocked persons must be deposited into the Foreign Government Deposit Funds under Executive Order 14373, with Secretary Marco Rubio confirming about $200 million is moving from Qatar to a U.S. Treasury blocked account.
  • Exports to destinations outside the United States require detailed reports within 10 days of the first transaction and every 90 days thereafter, in addition to heightened recordkeeping and diligence obligations.
  • The license bars upstream activity and prohibits non‑commercial payment terms, crypto or gold settlements, transactions tied to Russia, Iran, North Korea, Cuba, certain China-linked ownership, and any use of blocked vessels; OFAC may amend or revoke the authorization at any time.