Venezuela – Situation Update
For updates on the ongoing situation in Venezuela, please refer to the attached circulars from the Club’s listed correspondent, Globalpandi SA
Publications
Venezuela Oil Sector Reforms and Sanctions Relaxation – January 2026
On 29th January 2026 the US issued Venezuela General Licence 46, providing wider authorisation than under previous licences for transactions involving Venezuelan-origin oil. GL 46 authorises transactions including those involving PdVSA and the Government of Venezuela. Transactions are authorised provided that any contract that involves the Venezuelan government, PdVSA, or its subsidiaries, contains US law and dispute resolution clauses. . Permitted activities are those “…ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, including the refining of such oil, by an established U.S. entity…”. It extends to the export/sale/supply of Venezuelan-origin oil to countries other than the United States, subject to compliance with reporting requirements setting out details of the activities involved including quantities and values of cargoes.
Under the licence any payments made to a US sanctioned person would need to be made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of 9th January 2026, or otherwise as specified by the US Treasury.
The licence does not permit payment terms that are not commercially reasonable, which involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro. Transactions involving persons located or domiciled in Iran, North Korea, Cuba and China are also prohibited. Also prohibited are transactions involving Venezuelan or US entities that are owned or controlled by Chinese entities.
The Club’s Venezuela correspondent GlobalPandi has published the attached Circular which sets out how the above developments operate in tandem with legislative changes in Venezuela implemented by the National Assembly in the new Hydrocarbons Law of 29th January 2026. We are grateful to GlobalPandi for their permission to publish their informative alert.
