GL 49A: The license that allows negotiation without execution — and why it matters most for investors who haven't entered yet
GL 49A authorizes something previously impossible: negotiating and signing contingent investment contracts in oil, gas, petrochemicals, and electricity without prior OFAC approval.
GL 49A authorizes something that was previously impossible: negotiating and signing contingent investment contracts in oil, gas, petrochemicals, and electricity without requiring prior OFAC approval. The condition: each contract must include an explicit contingency clause regarding OFAC authorization for execution. It is the deal-making license.
GL 49A does not authorize investment. It authorizes the step prior to investment: negotiation, due diligence, and the signing of agreements that are only executed if OFAC authorizes them. It seems minor. It is not. Before GL 49A, a U.S. company could not legally sit at a negotiation table with PDVSA to discuss an investment contract. It could not send geologists. It could not hire lawyers to evaluate a block. It could not sign an MOU. Each of those activities required a specific OFAC license.
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GL 48D — Supply of Goods and Services to Venezuela
Authorizes the supply from the U.S. or by a U.S. person of goods, technology, software or services for oil, gas and petrochemical exploration, development and production —including maintenance and repair of equipment—, and for electricity generation, transmission, storage and distribution in Venezuela. As of September 28, 2026, the petrochemical annex lists methanol. The formation of new joint ventures remains outside the license. Supersedes GL 48C.