OFAC Clarifies Operating Conditions for Venezuela Energy Sector
The FAQs published on April 1 strip out the ambiguity over payments and geopolitical carve-outs under GL 46B, 51A and 52.
Treasury's new FAQ framework establishes clearer pathways for energy investments while maintaining strict payment channeling requirements and geopolitical exclusions.
OFAC's April 1 FAQ publication is not routine regulatory housekeeping. The Treasury's clarification on payment channeling through Foreign Government Deposit Funds creates a defined compliance pathway that was previously ambiguous. This mechanism allows transactions with blocked entities while maintaining Treasury oversight — a critical distinction for institutional investors evaluating Venezuelan energy exposure. The simultaneous removal of Delcy Rodriguez from the SDN List underscores a calculated signaling approach by the Biden administration.
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FURTHER READING
04Washington clears the rebuilding of Venezuela's network and leaves the capital waiting on another license
Through Thursday the telecommunications license covered carrying traffic; since Friday it covers installing, repairing and operating the plant itself. Putting capital into it still needs a permit that does not exist yet.
Venezuela Upstream July 2026: LOH Regulation drops PDVSA (Gaceta 7,052), Repsol signs Horcón MoU, OFAC amends GL 46C-54A, Brent normalizes to $81
The first comprehensive Hydrocarbons Law regulation since 1943 opens upstream to privates without a mandatory joint venture; the VE Score eases from 94 to 84 on Brent's correction (May $104 → July $81), not regulatory deterioration.
OFAC eligibility in Venezuela: who lends the permit to sign with PDVSA
A Canadian oil company set out on August 24 the six steps it took to enter Venezuelan crude: a U.S. subsidiary, registration with the investment agency, exclusivities, data packages and a field visit. Five it took alone. For the sixth it states that it partners "with entities benefiting from the updated U.S. sanctions regime."
GL 46C — Trade in Venezuelan-Origin Oil and Petrochemical Products
Authorizes an established U.S. entity to lift, export, sell, store, transport and refine Venezuelan-origin oil —and to import Venezuelan-origin petrochemical products into the U.S.— in transactions involving the Government of Venezuela and PdVSA, subject to U.S./allied law and forum and Treasury payment routing. Supersedes GL 46B.