The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has taken a key step in its policy toward the South American country. Through the issuance of General Licenses No. 46E, No. 48D, and No. 49B, the agency seeks to moderately ease restrictions on activity in key Venezuelan energy, petrochemical, and electrical infrastructure sectors. These provisions, which supersede their predecessors, open specific channels for U.S. businesses under strict oversight and compliance guidelines.
General License 46E pertains to the marketing and import of hydrocarbons. This instrument formally authorizes established U.S. entities to manage the purchase, sale, transportation, refining, and marketing of Venezuelan petroleum and petrochemical products destined for the U.S. market. The regulations permit the contracting of logistical services at local ports and along maritime routes, but impose very clear financial restrictions: the use of state-issued cryptocurrencies such as the Petro, payments in gold, and any debt restructuring schemes are strictly prohibited.
Another general license is 48D, which addresses technical support and the provision of operating goods. It is aimed at revitalizing the productive infrastructure; this license authorizes the supply of goods, software, technology, and specialized services for the exploration and production of gas, oil, and petrochemical derivatives, as well as for electricity generation, transmission, and distribution systems. While it facilitates the maintenance and repair of existing facilities, the measure maintains severe restrictions, expressly prohibiting the export or re-export of diluents to Venezuela and the direct creation of new joint ventures.
Finally, there is the general 49B license, which covers the preparatory phase and contingent contracts. It is designed to lay the groundwork for future projects; this authorization allows companies to negotiate and enter into contingent contracts, as well as conduct audits and legal, technical, and environmental due diligence processes. However, the legal framework establishes an essential restrictive condition: no agreement under this license can be executed or involve financial disbursements or practical operations until the parties have obtained a specific and independent license issued directly by OFAC.
Common guidelines and geopolitical restrictions
The regulatory package operates under a strict regulatory framework that explicitly defines authorized fertilizers and petrochemicals—such as urea, methanol, ammonia, and sulfuric acid. Key conditions include the requirement to submit any dispute resolution to courts or arbitration tribunals in the United States, the United Kingdom, France, or Singapore, and the centralization of payments in official accounts designated by the U.S. Treasury.
Furthermore, the licenses reaffirm the absolute ban on any operation or transaction that directly or indirectly involves individuals, companies, or interests from Russia, Iran, North Korea, Cuba, and China. Finally, the beneficiary companies are subject to rigorous transparency mechanisms, requiring them to submit detailed reports on volumes, amounts, and taxes within ten days of their first transaction and subsequently every 90 days.
