OFAC Outlines Mandatory Payment Procedures for the Foreign Government Deposit Funds Account (FAQ 1239)

On July 24, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated FAQ 1239. This guidance establishes the mandatory protocol for entities seeking payment account information to execute authorized deposits into the Foreign Government Deposit Funds (FGDF) account, consistent with Executive Order 14373 ("Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People") and related Venezuela General Licenses.

Key Takeaways

• Mandatory Contact Protocol. Depositors must email the official Department of State point of contact at DepositorInquiries@state.gov before making any payment. OFAC expressly warns that failing to submit this prior notification with the required transaction details may result in the rejection of deposits.
• Required Transaction Disclosures. To obtain payment account details, potential depositors must be prepared to provide comprehensive information, including:
  • Full legal names and addresses of the corporate depositor, subsidiaries, and all contract parties.
  • A detailed description of the underlying contract or obligation, including payment nature, purpose, product type, and amounts.
  • Sales dates, corresponding invoices, contract numbers, and reference identifiers.
  • Total payment amount, currency, and proposed payment date(s).
  • Identification of the specific General License authorizing the underlying transaction.
  • Supporting transaction records to validate the deposit, along with primary contact details for follow-up inquiries-
• Official Confirmation of Payment. Once the Department of State provides the payment details and the deposit is accepted, the depositor will receive a confirmation email acknowledging receipt. This confirmation may be used to inform and verify compliance with all contracting parties involved.

Disclaimer

This report is prepared for informational purposes only and does not constitute legal advice. The interpretation and application of OFAC sanctions regulations is 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 this FAQ guidance or the underlying Executive Orders and 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.