On 29 January 2026, US OFAC published general license No. 46 (as amended by general license No. 46A) which authorises, in essence, any transactions with Venezuelan oil, provided that:
- The transaction is with an established U.S. entity (which in essence locks-out any non-US companies from trade with Venezuela);
- Any payments to Venezuela for such oil will be made to a US blocked account;
- No transactions shall involve Russian, Chinese, Iranian, Cuban, or North Korean entities ;
- The relevant contracts shall be governed by US law/subject to the jurisdictions of the US courts; and
- Terms shall be arms’-length and payments may not involve gold or crypto currencies.
The license clearly locks-out any non-US companies from dealing in Venezuelan oil. FAQs (1226 – 1235) issued by OFAC confirm the point that, for example, EU companies may be involved only in connection with supporting services (e.g., insurance or shipping), but cannot actually purchase oil.
Nevertheless, the issue of this license in an important step in the relaxation of the US sanctions against Venezuela and, hopefully, it is the first step in this process. The US sanctions against Venezuela are one of the most comprehensive national sanctions’ regimes. For the overview of the international economic sanctions against Venezuela, please see our video.
Further to above, on 3 February 2026, OFAC published another general license No. 47. It permits to sell to Venezuela of diluents. These are critical for the marketability of Venezuelan crude, given that this is a very heavy oil. Similar to license 46, the license permits transactions only with US-origin diluents.
On 10 February 2026, OFAC issued general license No. 30B which authorises all transactions with Instituto Nacional de los Espacios Acuaticos (INEA) of Venezuela and general license No. 48 which authorises provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, or production of oil or gas in Venezuela (subject to the same conditions as general license No. 46).
On 13 February 2026, OFAC published general license 50 (as amended on 18 February 2026 by general licence 50A,), whereby the following EU oil corporations (and their subsidiaries) were added to a list of entities authorised to deal in Venezuelan oil subject to the conditions set out above. These companies are:
BP PLC
Eni S.p.A.
Établissements Maurel & Prom SA
Repsol S.A.
Shell PLC
This is an important step demonstrating that the US are willing to allow certain presence of non-US business in Venezuela.
Similarly, on 13 February 2026, OFAC issued general license 49 which negotiation of and entry into contingent contracts for new investment in oil or gas sector operations in Venezuela are authorized, provided that the performance of any such contract is made expressly contingent upon separate authorization from OFAC.
