General License 52: A Shift in US–Venezuela Energy Policy

On 18th March 2026 the US Treasury published General Licence 52, relaxing existing US sanctions against PdVSA and the Government of Venezuela. The licence permits US companies to re-enter Venezuela’s oil and gas sectors without needing to apply for specific OFAC licenses. GL 52 can be relied upon on condition that certain contractual and payment requirements are satisfied. GL 52 follows from earlier steps taken by the US government to allow US companies to benefit from Venezuela’s energy sector.

Transactions involving PdVSA otherwise prohibited under Executive Orders 13884 and 13850 are permitted provided that any contract for such transactions includes a US governing law and dispute resolution clause, and any monies payable to a sanctioned person are made into the US “Foreign Government Deposit Funds”,  or any other account as instructed by the US Treasury.

As well as relaxing sanctions against PdVSA, General Licence 52 also authorises transactions with the Government of Venezuela otherwise prohibited under Executive Order 13884, again provided that any sums payable to the Government of Venezuela are directed to the US Foreign Government Deposit Funds or any other accounts as instructed by the US Treasury.  

GL 52 does not authorise dealings with US designated persons other than PdVSA, persons linked to Russia, Iran, North Korea or Cuba, or Chinese owned or controlled entities in Venezuela or the US, or involving designated vessels.

If GL 52 is relied on by a person to export, reexport, sell, resell, or supply Venezuelan-origin oil or Venezuelan-origin petrochemical products to countries other than the United States, that person is under an obligation to provide a report outlining details to specified US government departments. Such reports to be submitted within ten days after the execution of the first of such transactions and every 90 days thereafter while such transactions are ongoing.