Overview
- OFAC’s General License 46, issued Jan. 29, authorizes established U.S. entities to lift, trade, store, transport and refine Venezuelan-origin oil, but it does not permit exploration, drilling or production.
- Contracts with the Venezuelan government or PDVSA under GL 46 must be governed by U.S. law with dispute resolution in the United States, and qualifying entities must have been organized in the U.S. on or before Jan. 29, 2025.
- Payments to blocked persons must flow to a Treasury-designated Foreign Government Deposit Fund under Executive Order 14373, with officials confirming initial proceeds are held in Qatar pending transfer to a U.S. Treasury blocked account.
- The license bars dealings tied to Russia, Iran, North Korea or Cuba, restricts certain China-linked ownership, prohibits non‑commercial payment terms including specified crypto and gold arrangements, and requires reporting to State and DOE for non‑U.S. destination sales within 10 days and every 90 days thereafter.
- Multiple outlets report the administration is preparing a separate general license to allow upstream production in Venezuela as soon as this week, with the White House signaling work to enable investment even as major oil firms weigh legal, security and investment risks; OFAC has not announced such a license.