Navigating the New OFAC Framework: Structural Updates to Venezuela General Licenses and FAQs

On June 10, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) comprehensively updated seven key General Licenses (GLs 46C, 47A, 48B, 50B, 51B, 52A, and 54A) governing operations in Venezuela’s oil, gas, electricity, and mining sectors, alongside the issuance of two guidance documents: FAQs 1259 and 1260.

These amendments reflect a strategic shift toward a more practical framework for authorized transactions. While the substantive commercial authorizations for established operators remain largely intact, this update introduces critical structural enhancements designed to provide greater contractual certainty and facilitate the management of cross-border operations and logistics.

The most significant updates include:

• Expanded Dispute Resolution Forums. Previous iterations of these licenses rigidly confined dispute resolution exclusively to the United States. The updated framework significantly resolves this operational bottleneck, permitting dispute resolution proceedings to be seated in established, neutral international forums, specifically adding the United Kingdom, France, and Singapore alongside the United States. This expansion provides parties with access to internationally recognized forums, which is expected to materially facilitate the structuring and financing of transactions involving Venezuela.
• Resolution of the "Governing Law Tension". Supported by the newly issued FAQ 1260, OFAC has provided a much-needed structural split regarding applicable law. While core contractual interpretation, performance obligations, breach, contractual remedies, payment obligations, termination, validity, assignment or novation, and enforceability of the contract must still be governed by the laws of a U.S. state or jurisdiction, OFAC explicitly clarified that contracts may recognize Venezuelan sovereign regulatory authority. Contracting parties can now safely integrate local Venezuelan law to govern administrative permits, concessions, labor mandates, environmental regulations, and health and safety standards.
• Aviation and Logistical Flexibility. Providing crucial relief for corporate flight operations and personnel logistics, FAQ 1259 confirms that private and commercial flights are authorized to utilize Venezuelan airports and access associated ground services pursuant to GL 30B. Furthermore, GL 33 expressly authorizes transactions necessary for overflights, emergency landings, and air ambulance or medical evacuation services, ensuring robust operational safety for international personnel.

Unaltered Compliance Guardrails

Despite the newfound contractual and logistical flexibility, OFAC maintains rigorous financial and geopolitical controls, confirming that Treasury intends to permit authorized activity while maintaining close regulatory oversight. Covered entities must continue navigating the following strict boundaries across the energy and mining sectors:

• Centralized Financial Routing. Monetary payments to blocked persons (excluding local taxes, permits, or fees) must still be channeled through the Foreign Government Deposit Funds pursuant to Executive Order 14373 or other Treasury-instructed accounts.
• Prohibited Payment Mechanisms. Debt swaps, payments in gold, and transactions utilizing Venezuelan digital currencies (such as the petro) remain expressly prohibited.
• Geopolitical Exclusions. Across the board, transactions involving individuals, entities, blocked vessels, or joint ventures linked to the Russian Federation, the People's Republic of China, Iran, North Korea, or Cuba remain strictly barred.
• Mandatory Multi-Agency Reporting. High-frequency transaction reporting to the Departments of State, Energy, or Interior (depending on the specific license) remains a mandatory condition.

Disclaimer

This report is prepared for informational purposes only and does not constitute legal advice. The interpretation and application of OFAC sanctions regulations are a complex area of U.S. law. Companies are strongly encouraged to consult qualified U.S. sanctions counsel before taking any action in reliance on these updated General Licenses. LEC Abogados is a Venezuelan law firm and does not practice U.S. law or provide advice on OFAC regulations. Information is current as of the date of publication.