Venezuela's OFAC licenses: the Federal Register prints the version no longer in force

The U.S. Treasury took four Venezuela general licenses to the Federal Register on Friday. Three of the four had already been superseded by the time they appeared in print. The one authorizing six foreign oil companies to operate with PDVSA came out carrying a contract condition that stopped being required on August 27.

The difference between the two places a license lives is not a filing detail. The Federal Register is the U.S. government's official publication: what runs there is incorporated into the Code of Federal Regulations, which for this program is part 591 of title 31. The website of the Office of Foreign Assets Control is where a license is announced the day it is signed. Whoever drafts a contract consults one of the two. Not always the same one.

In the Venezuela file, the distance between them reached seven months on Friday. General license 30B was signed on February 10 and published on September 11. License 50A, from February 18, came out the same day. License 51, from March 6, did too.

What was in force that same Friday

Of the four, only one matches what governs. License 30B remains the version in force on ports and airports, and its publication closes the circuit as it should. The other three describe a state of the regime that no longer exists.

The clearest case is the license governing oil operations for the six companies in the annex — BP, Chevron, Eni, Maurel & Prom, Repsol and Shell. The Federal Register printed version A, from February. Version C has governed since August 27, and there was a version B in June in between.

The clause that changed, in both texts

They are worth reading back to back, because the difference fits in one line and decides how a multi-year contract gets drafted.

A lawyer drafting today from the published text will write a U.S.-law clause the authorization no longer asks for, and will leave out three admitted seats: London, Paris and Singapore. Neither of those voids the contract. Both narrow the Venezuelan side's position for no reason, and the foreign party that notices has a free argument at the table.

How much of the regime in force is published

The Venezuela program today lists forty-three general licenses on the office's website. The Federal Register holds fifty-one documents from this program since 2015, and none later than Friday.

The ones holding up the 2026 commercial architecture appear in none of them. The license authorizing an established U.S. entity to deal with PDVSA, the coal-and-minerals one, the one covering supply of goods and services, the one for contingent investment contracts, the telecommunications one and the 2020 bond one were all signed between February and September of this year and exist only as files on a web page. The Code of Federal Regulations does not carry them.

Friday's issue carries one more figure that sizes the lag without needing interpretation. Its pages also ran general license 35 from another program, the one authorizing wind-downs under the global terrorism and illicit drug trade regulations. That document carried its own expiration date in print: May 14, 2026. It was published four months after it lapsed.

What to do with this

For anyone negotiating, the operating rule is short: the binding text is the signed PDF on the office's website, with its date and its letter, and that letter has to be checked the day the contract is signed, not the day drafting began. The Federal Register version serves the record. For the clause, it does not.

The indicator is the bulletin itself. If versions C and D — the oil one and the minerals one — show up published in the coming weeks, the gap was administrative queue and it is closing. If what runs is the next superseded version while the one in force stays out, the reading is different: the Federal Register is documenting the archive, not the regime. Those are two different things and only one binds.