U.S. Treasury’s Office of Foreign Assets Control issued new licenses that broaden permissible activities in Venezuela’s oil, mining, and port operations, under stringent compliance requirements. These developments aim to facilitate controlled reactivation of Venezuela’s energy and mineral industries, while maintaining strict restrictions on transactions involving sanctioned actors and payment methods.
The U.S. Treasury Department’s OFAC released a series of general licenses updating the sanctions regime covering Venezuela’s oil, petrochemical, mining, and logistics sectors. Licenses 46A, 48, and 30B authorize U.S. entities to engage in the marketing, transport, refining, and provision of goods and services for the Venezuelan hydrocarbons sector, including PDVSA and its subsidiaries, conditioned on contractual adherence to U.S. law and financial controls. Specifically, License 46A permits activities such as export, storage, and transportation of Venezuelan crude oil through U.S.-established companies with payments to blocked persons routed into specially controlled government accounts. The license excludes dealings with entities linked to Russia, Iran, North Korea, Cuba, and Chinese-controlled firms, forbids the use of cryptocurrencies and gold payments, and prohibits transactions involving sanctioned vessels or debt swaps. License 48 authorizes the supply of equipment, technology, and related services for exploration, production, and maintenance of oil and gas infrastructure, also under U.S. jurisdiction and payment oversight. License 30B covers essential transactions for operating Venezuelan ports and airports, limited solely to routine and necessary activities, excluding dealings with blocked entities under separate sanction programs.
Complementing these are new licenses 51A, 54, and 55 for the mining sector, permitting U.S. companies to export, purchase, transport, and engage in mineral commerce— including gold—subject to U.S. legal frameworks and judicial oversight. License 54 authorizes mining-related supply chains, while License 55 enables negotiation of future investment contracts and joint ventures, though direct operations within Venezuela require additional permissions. The updated guidance tightly restricts nontraditional payment mechanisms such as cryptocurrencies and debt-for-equity swaps, and forbids economic ties with actors influenced by geopolitical adversaries including Russia, Iran, China, and North Korea. The sanctions regime continues to prohibit transactions involving PDVSA bonds or debt instruments and prohibits altering ownership of blocked assets. Violations could trigger severe penalties and are deemed support for sanctioned entities or corruption schemes. These calibrated regulatory adjustments reflect U.S. aims to selectively reopen Venezuelan energy and mining markets under rigorous compliance and geopolitical risk controls.
