Venezuela General License 52 - Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A. (March 18, 2026)

Date issued: Mar. 18 2026

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TURBOFAC Commentary (288 words)

Notes:

1) Compare and contrast Venezuela General License 46B and other oil/gas-related GLs issued subsequent to GL 46. This GL is similar to those GLs insofar as it features similar payment and contractual conditions (for comments concerning those provisions, see comments to GL 46). While there are many PdVSA-related transactions that could be covered by both GL 52 as well as other Venezuela-related GLs focusing on oil and gas (i.e. GLs 46-50), the scope of this GL does differ substantially from the others, in some ways that make the GL narrower than the others and in some ways that make is broader.

2) On the broader side, this GL authorizes “all transactions…involving Petróleos de Venezuela, S.A.,” which is essentially all transactions that are within the scope of the blocking prohibition due to PdVSA involvement. There are no...