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OFAC eases contracting with PdVSA officials while shielding Citgo governance

OFAC has amended its license for dealings with Venezuela’s state oil company, giving sanctioned PdVSA officials authority to sign permitted contracts while adding new protections around Citgo’s corporate governance.

2 min read

WASHINGTON, September 14, 2026 — US Treasury issued Venezuela General License 52C, expanding the ability of US companies to execute transactions involving state oil company Petróleos de Venezuela, or PdVSA, while imposing an additional restriction covering Citgo governance.

The license replaces General License 52B, issued Aug. 27, and retains broad authorization for established US entities to conduct transactions with PdVSA and companies it owns at least 50%. Permitted activities include buying, selling, transporting and marketing Venezuelan oil and petroleum products, supplying goods and technology to the oil and gas sectors, entering new investment contracts and forming joint ventures.

The principal change is that blocked individuals may now execute and sign contracts, agreements and other transaction documents when acting solely in their official capacity as officers, employees or authorized representatives of PdVSA or its majority-owned entities. General License 52B did not contain that authorization.

The amendment removes a potential practical obstacle for companies seeking to enter transactions already permitted by OFAC. PdVSA remains blocked, but designated officials can now perform the formal signing functions needed to complete authorized deals without those actions themselves violating US sanctions.

At the same time, OFAC added an explicit prohibition on transactions intended to affect or alter the governance of PDV Holding Inc., Citgo Holding Inc. or Citgo Petroleum Corp., including the appointment, removal or replacement of directors or officers. That restriction was not included in General License 52B.

Other core restrictions remain. The license does not authorize prohibited dealings in certain Venezuelan government or PdVSA debt and equity, transactions involving blocked vessels, or specified dealings involving Russia, Iran, North Korea and Cuba. It also excludes certain Venezuela- or US-based entities linked to Chinese persons.

Payments to blocked persons generally must continue to be directed into Treasury-specified Foreign Government Deposit Funds or another account designated by Treasury, while contracts with PdVSA must provide for dispute resolution in the United States, United Kingdom, France or Singapore.

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Structured data extracted from official sources and validated by sanctions experts

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