OFAC issues FAQ clarifying sanctions risk for non-U.S. persons using Venezuela GLs

WASHINGTON, March 31, 2026 — The U.S. Treasury Department’s Office of Foreign Assets Control published Venezuela-related FAQ 1247 on Tuesday, clarifying that non-U.S. persons generally will not face U.S. sanctions exposure for engaging in transactions authorized by General Licenses 46B, 51A and 52, provided specific conditions are met. OFAC announced the new guidance in a recent action posted March 31.

The FAQ says the licenses, subject to conditions, authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A., or PdVSA, as well as certain transactions ordinarily incident and necessary to the exportation, sale, supply, storage, purchase, delivery or transportation of Venezuelan-origin oil, petrochemical products or minerals, including gold.

OFAC said non-U.S. persons may transact under those authorizations, including with PdVSA or by importing Venezuelan-origin oil, petrochemical products or minerals into a third country, if the non-U.S. entity was organized in a third country on or before Jan. 29, 2025, payments to blocked persons are routed to the Foreign Government Deposit Funds or another Treasury-directed account, and payment terms are commercially reasonable. The agency also said transactions cannot involve debt swaps or certain Venezuelan digital currencies, including the petro.

The FAQ further excludes transactions involving persons tied to Russia, Iran, North Korea or Cuba, as well as certain Venezuela- or U.S.-based entities owned or controlled by, or in joint venture with, persons from China. It also bars transactions involving blocked vessels. For GL 51A, OFAC added that authorized transactions cannot involve processing or refining Venezuelan-origin minerals in Russia, Iran, North Korea, Cuba or China.

OFAC warned that non-U.S. persons that continue to transact with PdVSA or import Venezuelan-origin oil, petrochemical products and minerals without complying with those conditions risk designation, including for supporting blocked persons or engaging in deceptive or corrupt transactions involving the Government of Venezuela. The FAQ also notes that GL 52 carries additional restrictions tied to other Venezuela-related executive orders, including certain bond, debt, lien and judicial-process matters.