Venezuela sanctions: OFAC’s GL 52C lets sanctioned PDVSA officials sign the contract

Eighteen days. That is how long the previous version lasted of the permission governing business with Venezuela’s state oil company. Today’s brings the missing gesture: putting pen to paper, barred until last night whenever the signing hand belongs to someone sanctioned by Washington.

General License 52C replaces GL 52B of August 27 in its entirety and adds two paragraphs that were not there; beyond them the document is unchanged, with the same seat for disputes, the same routing of payments and the same country exclusions. The signature of the director of Treasury’s sanctions office is time-stamped 8:27 this morning.

Why putting a signature on paper counted as a transaction

Nothing in the sanctions regulations scales with the size of the act. Buying a cargo from someone on the Specially Designated Nationals list and accepting a paper that person signed fall on the same side of the line: both are dealings with them. And a contract with the state company is signed by whoever holds authority to represent it. The license text assumes some of those officers are blocked persons; hence the separate paragraph authorizing it.

That was precisely the missing piece. Since January the framework had settled who may contract, under which law, before which forum and through which account the money moves; what never had an answer was who could put a name at the bottom on the Venezuelan side. Without it, the rest was architecture with no door.

What a deal needs in order to hold

Five conditions govern a deal under this license today, and only one of them just moved. On the buying side there has to be an established U.S. entity: a company organized in the United States on or before January 29, 2025, so a vehicle set up for the occasion will not do. The deal must take its disputes to the United States, the United Kingdom, France or Singapore, though since August 27 the governing law is the parties’ to choose. Every payment to a blocked person — bar local taxes, permits and fees — goes into the Treasury custody account created by Executive Order 14373. Anyone placing Venezuelan crude or petrochemicals outside the United States answers to the State and Energy departments: parties, volumes, values, final destination and what was paid to the Venezuelan treasury, ten days after the first transaction and every ninety while it continues.

And the fifth, the one that changed today: who may sign for the state company. Now a blocked official as well, in their capacity as officer, employee or authorized representative of the oil company or its entities.

The act is authorized, the person is not

Little is authorized, and precisely. What comes in are transactions "ordinarily incident and necessary to the execution and signing of contracts, agreements, or other transaction documents" by blocked individuals, and only to effect what the opening paragraph already allowed. The general exclusion still stands a few lines below: dealing with someone on the list remains prohibited. What changed is that it now opens with a carve-out — "except as authorized by paragraph (c)" — that it did not carry before.

Holding the signed contract is one thing; paying the person who signed it is another. A U.S. company may keep the valid document in hand; it may not, under this license, compensate that official, hire them or do business with them in their own right. What clears is the step that stalled the deal, not the relationship with whoever executes it.

Citgo enters the text through the exclusions

From Petróleos de Venezuela to PDV Holding, and on to CITGO Petroleum, runs the chain holding the Venezuelan asset on U.S. soil: precisely what a creditor with a judgment would want to reach. The license now names it company by company in order to place it out of reach. Operate under this permission and you may buy crude and stand up a joint venture in the Orinoco; you may not touch a board seat in Delaware. On why that structure still cannot be executed against despite a valid pledge: the 2020 bond analysis.

Accompanying the text is a single amended frequently asked question, 1245, describing what the license authorizes and restating both changes. There is no new question. In the August 27 amendment the agency did explain in its own words that it was acting "in response to investment-related reforms made by the GOV since January 2026"; today’s text comes with no note of that kind, so the motive is undocumented.

What did not move

Reading word for word as before are the prohibitions that stand between a creditor and payment: Executive Order 13808 on bonds and debt, 13835 on equity interests, and the bar on enforcing liens, judgments or arbitral awards against blocked property. Untouched too are the exclusions covering Russia, Iran, North Korea and Cuba, and entities owned or controlled by — or in a joint venture with — persons in China.

For the U.S. side of the table the entry conditions are the familiar ones, and corporate vintage remains the filter deciding who gets a seat: who supplies the permission to sign with the state company.

Nothing in the document will show whether the new paragraph is worth anything. The first contract signed under GL 52C will, and so will the office held by whoever signs it for the state company.