Venezuela General License 56 - Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela (April 14, 2026)

Date issued: Apr. 14 2026

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TURBOFAC Commentary (724 words)

Notes:

[*See General Note on Authorizations Concerning Venezuelan Debt Restructuring (System Ed. Note)]

1) This is one of three “contingent contracts” GLs issued as of the date of the issuance of GL 56. The other two (Venezuela GL 49 and Venezuela GL 55) license against the entirety of the VSR but are sector specific, while this GL licenses against EO 13884 only, but is not bounded by economic sector. This GL does not have the “Note 2 to Paragraph (a)” that the others have, but it should be assumed that transactions “ordinarily incident and necessary to engaging in commercial-related negotiations of contingent contracts” can include the “include prefatory steps for the aforementioned activities, such as conducting commercial, legal, technical, safety, and environmental due diligence and assessments” that are explicitly described as covered in the context...