OFAC issues Venezuela GL 52, opens path for certain U.S. dealings with PdVSA

WASHINGTON, March 18, 2026 — The U.S. Treasury’s Office of Foreign Assets Control has issued Venezuela-related General License 52, authorizing certain transactions involving Petróleos de Venezuela, S.A., or PdVSA, and entities it owns 50% or more, subject to conditions and exclusions. OFAC also released two related FAQs, 1245 and 1246.

The license permits transactions otherwise barred under Executive Orders 13884 and 13850 for “established U.S. entities,” defined as entities organized under U.S. law on or before Jan. 29, 2025. Contracts with PdVSA must be governed by U.S. law, with disputes resolved in the United States, and payments to blocked persons, other than local taxes, permits or fees, must be directed to Foreign Government Deposit Funds or another account designated by Treasury.

FAQ 1245 says authorized activity includes lifting, exporting, transporting, storing, marketing and purchasing Venezuelan-origin oil and petroleum products; supplying diluent, goods, services and technology needed for oil, gas or petrochemical operations; entering new investment contracts; forming new joint ventures in Venezuela; and related commercial, legal, technical, safety and environmental due diligence.

The authorization does not extend to dealings otherwise barred by the Venezuela Sanctions Regulations, including PdVSA bonds and debt, equity transfers, enforcement of liens or judgments, transactions involving other SDNs, non-commercial payment terms, debt swaps, gold payments, petro-linked payments, blocked vessels, or dealings tied to Russia, Iran, North Korea, Cuba, and certain China-linked structures in Venezuela or the United States.

The license also imposes reporting requirements for exports or resales of Venezuelan-origin oil or petrochemicals to destinations outside the United States, with reports due within 10 days of the first transaction and every 90 days thereafter.

In FAQ 1246, OFAC said GL 52 does not authorize the sale of certain CITGO shares at issue in the Crystallex case, stating that a specific license is still required before any sale can be executed.