Venezuela General License 48A - Authorizing the Supply of Certain Items and Services to Venezuela (March 13, 2026)

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TURBOFAC Commentary (312 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 Venezuela General License 46 (oil trading) and Venezuela General License 47 (diluents). This authorizes “provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, or production of oil or gas in Venezuela,” subject to make of the same conditions and under a similar structure as the other two GLs. The interpretive note to paragraph (a), which serves as an implicit interpretation of the term “ordinarily incident and necessary to” in the context of the transactions authorized, helpfully confirms that this includes “transactions for the maintenance of oil or gas operations in Venezuela, including the refurbishment or repair of items used for oil or gas exploration, development, or production activities”.

2) A significant difference between this GL and the other two is that the “[a]ny transaction involving a person” carveout includes China.

3) Query: with respect to the reference to Venezuela GL 30B, when would reliance on that GL be needed for a transaction not otherwise authorized as ordinarily incident to a transaction covered in paragraph (a)?

4) See FAQ # 1237, concerning the scope of " local taxes, permits, or fees."

5) See FAQ # 1240 (defining "diluent" for purposes of GL 47, and query whether there is any reason to believe that the guidance does not apply equally to GL 46 and Gl 48).

6) See notable GL-specific guidance at FAQ # 1241.

7) GL reissued on 3-13-26 to add "petrochemical products in Venezuela, or for the generation, transmission, storage, or distribution of electricity in Venezuela" to the scope of the GL.

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Venezuela General License 48A - Authorizing the Supply of Certain Items and Services to Venezuela (March 13, 2026)

TURBOFAC Commentary (312 words)