Three New OFAC General Licenses Provide an Initial Framework for Operations and Investment in Venezuela’s Oil and Gas Sectors

Key Points

• Three GLs issued by OFAC last week—GL 48, GL 49 and GL 50  (replaced and superseded by amended GL 50A)—represent the Trump administration’s first significant actions providing sanctions relief related to upstream oil and gas sector operations in Venezuela.
• The issuance of these GLs bookended a trip by U.S. Secretary of Energy Chris Wright to Caracas, where he met with Venezuelan Interim President Delcy Rodriguez and delivered remarks emphasizing the Trump administration’s goal of increasing oil and gas production, among other things, to promote prosperity for the Venezuelan people.
• In brief, these GLs authorize the following activities:
  • GL 48: The provision of goods, technology, software and services from the United States or by a U.S. person for the exploration, development or production of oil or gas in Venezuela.
  • GL 49: The negotiation of and entry into (but not execution or performance of) contingent contracts for new investment in oil or gas sector operations in Venezuela.
  • GL 50A: Transactions related to the oil or gas sector operations of specified U.S. and non-U.S. energy companies and their subsidiaries.
• As discussed in recent Akin client alerts, OFAC initially issued GL 47 (replaced and superseded by amended GL 46A) and GL 47 to advance the Trump administration’s immediate and ongoing efforts to stabilize Venezuela’s economy, by more narrowly addressing:
  • GL 46A: The supply chain for Venezuelan oil, which had accumulated in quantities at the limit of Venezuela’s storage capacity.
  • GL 47: Sales of U.S.-origin diluents to Venezuela, which are essential to the production of Venezuelan crude oil.
• Although GLs 48, 49 and 50A include various limitations on authorized activities and parties, as well as conditions, reporting obligations and exclusions, they collectively represent an important further step in sanctions relief for Venezuela and appear to help lay the groundwork for future actions by the Trump administration to promote the rebuilding of Venezuela’s economy.
  • A media note issued by the U.S. State Department spokesperson states that “additional authorizations may also be issued as necessary in furtherance of President Trump’s vision.”

Overview of GLs

A. Scope of Authorizations

Subject to certain conditions and exceptions, general licenses (GLs) 48, 49 and 50A authorize the following:

• GL 48: All transactions that are ordinarily incident and necessary to the provision from the United State or by a U.S. person of goods, technology, software or services for the exploration, development or production of oil or gas in Venezuela. GL 48 clarifies that these transactions include the processing of payments, certain transactions related to the maritime transport of goods and transactions for the maintenance of oil or gas operations, including the refurbishment or repair of items.
• GL 49: All transactions that are related to the negotiation of and entry into contingent contracts for new investment in oil or gas sector operations in Venezuela, provided that the performance of any such contract is made expressly contingent upon separate authorization from U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) (the contingent contracts).
  • “Note 2 to Paragraph (a)” clarifies that transactions authorized by GL 49 include prefatory steps for such activities, such as conducting commercial, legal, technical, safety and environmental due diligence and assessments.
• GL 50A: All transactions that are related to oil or gas sector operations in Venezuela of the entities listed in the Annex to the GLs and their subsidiaries (i.e., as of February 18, 2026: BP PLC, Chevron Corporation, Eni S.p.A., Établissements Maurel & Prom SA, Repsol S.A. and Shell PLC).

B. Conditions and Obligations

GL 48 and GL 50A contain the following conditions and obligations, which are also included in GL 46A and GL 47:

• Specifying the applicability of U.S. governing law and dispute resolution in contracts with the Government of Venezuela (GoV), state-owned oil company Petróleos de Venezuela, S.A. (PdVSA) or entities in which PdVSA owns, directly or indirectly, a 50% or greater interest (PdVSA Entities), all of which remain blocked. 
• Routing of monetary payments to a blocked person (except for local taxes, permits or fees) into the “Foreign Government Deposit Funds” or other accounts as instructed by the U.S. Department of the Treasury.
• Providing detailed reports, according to specified timelines, to the U.S. State Department and the U.S. Energy Department that include the parties involved and other information for each transaction pursuant to the authorization.

C. Exclusions

The authorizations in GLs 48, 49 and 50A all contain exclusions related to transactions involving individuals or entities located in or organized under the laws of Iran, North Korea, Cuba, Russia or China, or any entity that is owned or controlled by or in a joint venture with such persons, transactions involving blocked vessels and the unblocking of any property.

GL 48 and GL 50A additionally contain exclusions related to commercial terms and currency denominations for payments.

Finally, GL 48 contains exclusions related to the exportation or reexportation of diluents to Venezuela and the formation of new joint ventures or other entities in Venezuela to explore or produce oil or gas. As discussed above, certain transactions related to the sale of U.S.-origin diluents to Venezuela are authorized by GL 47.

D. Export Controls and Other Requirements of Federal Agencies

Like the two preceding GLs, GLs 48, 49 and 50A specifically note that they do not relieve any person from compliance with the requirements of other Federal agencies, including U.S. export controls administered by the Department of Commerce’s Bureau of Industry and Security.

Analysis of Key Issues

Of the three GLs, GL 50A appears to authorize the broadest scope of activities, which could encompass not only the negotiation of and entry into—but also the actual performance of—contracts that could potentially include investments, the formation of joint ventures or other entities and the pursuit of new projects related to certain oil and gas operations in Venezuela. However, as noted above, the authorization applies only to the operations of a limited number of specified international oil and gas companies, which we understand already operate in Venezuela.

GL 49 explicitly addresses “new investment” in Venezuela’s oil and gas sectors as part of any contingent contracts that parties—regardless of jurisdiction—may negotiate or enter into with PdVSA or other blocked parties. As noted above, important prefatory steps for such activities are also allowed. The key limitation is that, as stated in the State Department media note and consistent with the language of GL 49, “[t]he Trump Administration will subsequently review for approval the proposed contracts to ensure they advance the interests of the American and Venezuelan people.” We anticipate that OFAC would use its specific licensing authority to authorize parties to execute and perform such proposed contracts, but the timing of the issuance of such licenses may depend on the volume of applications and the number of OFAC personnel to adjudicate them.

GL 48 broadens the scope of previous sanctions relief by authorizing the provision of certain U.S. items and services related to upstream oil and gas operations. According to the State Department media note, this GL will enable U.S. companies to “[repair] and [upgrade] Venezuela’s oil and gas infrastructure.” In the context of GL 49, however, activities such as “investment” or “contracts to develop or operate oil fields, blocks, or other concessions”— including associated negotiations with, e.g., PdVSA— appear to be beyond the scope of the authorization in GL 48. In any case, investment under GL 48 would be practically challenging due to the exclusion on forming new joint ventures or other entities in Venezuela “to explore or produce oil or gas.” This exclusion indicates that the authorization may, as a practical matter, apply largely to existing oil and gas field suppliers and services companies.

U.S. Policy Considerations and Risks 

Taken together, these general licenses demonstrate continued U.S. phasing and calibration of sanctions relief to support the revitalization of Venezuela’s oil and gas sectors consistent with U.S. policy priorities, while maintaining leverage over Venezuela’s newly led government. By focusing on the supply of items and services, GL 48 allows a relatively modest range of activities to help address the dilapidation of Venezuela’s infrastructure. The broader language in GL 49 and GL 50A appears to go farther in some respects, but these authorizations are subject to important limitations: any contingent contracts negotiated under GL 49 require separate approval from OFAC, while GL 50A authorizes transactions related to the oil and gas sector operations of specified major energy companies, allowing them to operate with fewer constraints.

Notably, all three GLs exclude transactions involving persons located in, or with certain affiliations to, China, Russia, Iran, Cuba and North Korea, reflecting a policy desire to minimize their involvement in Venezuela’s oil and gas industries. At the same time, these exclusions do not necessarily disrupt the ability of China to purchase Venezuelan oil. In recent years, China has been a significant buyer of Venezuelan crude, and OFAC clarified in its FAQ 1231 that GL 46A allows the resale of Venezuelan oil to China by an established U.S. entity.