Venezuela related General License 47, "Authorizing the Sale of U.S.-Origin Diluents to Venezuela."

Date issued: Feb. 03 2026

Last substantive commentary amendment:
Mar. 10 2026

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TURBOFAC Commentary (348 words)

Notes:

*This is one of several Venezuelan energy sector-related GLs issued since the U.S. military operation resulting in the capture of Nicolás Maduro. See Venezuela General License 46A, Venezuela General License 47, Venezuela General License 48, Venezuela General License 49 and Venezuela General License 50.

1) Compare/contrast Venezuela General License 46 (a “sister” GL modeled in a similar fashion). The GLs are modeled in a similar fashion and cover similar activities. Below are certain observations and interpretive questions that arise from the GL, especially when read in light of GL 46, which OFAC has yet to address with formal guidance.

a) How will “U.S. origin” be interpreted? A broad interpretation is “subject to the EAR,”...