OFAC Issues General License 52A Authorizing Certain Transactions Involving PdVSA

On June 10, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 52A. Effective immediately, this administrative update fully replaces and supersedes General License No. 52.

GL 52A maintains the core authorizations enabling "established U.S. entities" (organized on or before January 29, 2025) to engage in transactions otherwise prohibited by Executive Order (E.O.) 13884 or E.O. 13850 involving Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest. However, the updated framework introduces critical alignments regarding dispute resolution venues and contractual compliance frameworks.

The key components and compliance considerations of GL 52A include:

• Governing Law and Dispute Resolution Forums. Any contract executed under this license must require that its terms be construed and interpreted in accordance with the laws of a U.S. state or jurisdiction. Furthermore, GL 52A expands the authorized forums for dispute resolution proceedings, allowing them to take place in the United Kingdom, France, or Singapore, in addition to the United States.
• Carve-Outs for Local Regulatory Compliance. A newly integrated administrative note explicitly permits contracts to feature terms recognizing that certain operational elements within Venezuela are subject to local law. This encompasses compliance with Venezuela's sovereign regulatory authority, administrative permits, licenses, concessions, labor mandates, environmental regulations, and health and safety standards.
• Centralized Financial Routing. Monetary payments to a blocked person—excluding payments for local taxes, permits, or fees—must be directed into the Foreign Government Deposit Funds pursuant to E.O. 14373, or into any other account as instructed by the U.S. Department of the Treasury. Prohibitions against alternative financing mechanisms, including debt swaps, gold settlements, or digital currencies issued by the Venezuelan government (such as the petro), remain strictly enforced.
• Geopolitical Exclusions. Sanctions relief completely excludes blocked vessels or any transactions involving individuals or entities from the Russian Federation, Iran, North Korea, or Cuba. Crucially, the authorization explicitly bars any transactions involving entities organized under the laws of Venezuela or the United States that are owned, controlled, or operated as a joint venture with individuals or entities from the People's Republic of China.
• Third-Country Reporting Mandates. Operators exporting, reexporting, selling, reselling, or supplying Venezuelan-origin oil or petrochemical products to countries other than the United States pursuant to this license face ongoing compliance obligations.

Disclaimer

This report is prepared for informational purposes only and does not constitute a 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 GL 52A. 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.