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.
OFAC licenses in Venezuela: contracts with PDVSA no longer need U.S. governing law
The requirement arrived in January, loosened in June and vanishes today from eight licenses at once. What did not move in those seven months: the seat of disputes, the routing of payments through the Treasury, and the same six oil companies cleared to operate.
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.
GL 48C — 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, and for electricity generation, transmission, storage and distribution in Venezuela. As of August 27, 2026, the contract must only route disputes to the U.S., U.K., France, or Singapore. Supersedes GL 48B.