Venezuela General License 49A - Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela (March 13, 2026)

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TURBOFAC Commentary (307 words)

Notes:

1) *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.

2) On February 13, 2026, OFAC issued Venezuela General License 49 Venezuela General License 50, “ which authorize “all transactions… that are related to oil or gas sector operations in Venezuela” for certain listed entities that appear on the Annex to 50, and for all others, “all transactions… related to the negotiation of and entry into contingent contracts for new investment in oil or gas sector operations” (Gl 49). GL 50 features carveouts that are similar to the ones that first appeared in GL 46 (see comments thereto), most significantly the governing law/dispute resolution condition and the “Foreign Government Deposit Funds” condition (GL 50). GL 50 notably specifies that “payments of oil or gas taxes or royalties to the Government of Venezuela, PdVSA, or any PdVSA Entity must be paid into the Foreign Government Deposit Funds,” which serves as guidance indicating that “local taxes, permits, or fees” are not “oil or gas taxes or royalties”.

GL 49, by contrast, is a relatively standard “contingent contracts” GL (compare Iran GL I, Russia GL 131 and 560.536, which all have similar “contingent contracts” definitions). The interpretive “note to paragraph (a)” is specific to GL 49 and should have cross-programmatic implications for other “contingent contracts” GLs. More specifically, OFAC’s position is that the contingent contracts GL authorizes “prefatory steps…such as conducting commercial, legal, technical, safety, and environmental due diligence and assessments.”

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

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Venezuela General License 49A - Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela (March 13, 2026)

TURBOFAC Commentary (307 words)