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1247. Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46D, 51D, and 52B?
No, provided that non-U.S. persons comply with certain conditions outlined in GLs 46D, 51D, and 52B as described below. Subject to certain conditions, GLs 46D, 51D, and 52B authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), as well as certain transactions with the Government of Venezuela, including Carbones del Zulia S.A. (Carbozulia), PdVSA, or CVG Compania General de Mineria de Venezuela CA (Minerven) that are ordinarily incident and necessary to, among other activities, the exportation, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin oil, petrochemical products, minerals (including gold), or coal. Generally, non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized under GLs 46D, 51D, and 52B — such as transacting with PdVSA or...
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[UPDATE - FAQ amended on 9-2-26 to account for reissuance of GLs 46D, 51D, and 52B to add "coal" to the authorization scope]
1) OFAC’s guidance at FAQ # 7 states that “non-U.S. persons do not generally risk being sanctioned for engaging in or facilitating transactions for which a U.S. person would not require a specific license.” Meanwhile, Venezuela GLs Venezuela General License 46B, Venezuela General License 51 and Venezuela General License 52 each apply to transactions “by an established U.S. entity” (defined to mean “any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.” Given that actually being an “established U.S. entity” within the meaning of the GL is effectively a condition for use of the...