Venezuela General License 46 - Authorizing Certain Activities Involving Venezuelan-Origin Oil

Date issued: Jan. 29 2026

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TURBOFAC Commentary (1888 words)

Notes:

1) This is the first Venezuela-related GL issued by the second Trump Administration. It follows the U.S. naval “blockade” around Venezuela and seizure of oil tankers departing Venezuela, the military operation resulting in the capture of Nicolás Maduro, the elevation of Delcy Rodríguez from Vice President to Acting President of Venezuela, and a “sweeping reform” to Venezuela’s hydrocarbons law which favors private actors operating in the country (see https://www.spglobal.com/energy/en/news-research/latest-news/crude-oil/011526-new-venezuela-hydrocarbons-law-to-include-production-participation-contracts-rodrguez). As of this writing, the GL is yet to be interpreted by official FAQ guidance or otherwise discussed on record by Administration officials in a way that would provide insight into the scope and operation of the GL.

2) The GL resembles the broader Venezuela General License 44 in some respects, but is sui generis in many respects in terms of the novel...