US government authorizes US entities to conduct certain transactions related to oil and gas sector operations in Venezuela

On February 13, 2026, the United States Department of Treasury’s Office of Foreign Assets Control (OFAC) published two new Venezuela-related General Licenses (GLs): GL 49, which authorizes negotiations of, and entry into, contingent contracts for certain investment in Venezuela, and GL 50, which authorizes certain transactions related to oil or gas sector operations in Venezuela.

These authorizations build on the prior licenses described in our recent DLA Piper alert.

Below, we provide a brief overview of the GLs and their implications for businesses seeking to engage with or re-enter the Venezuelan oil market.

General License 49

GL 49 authorizes all transactions related to the negotiation of and entry into contingent contracts for new investment in oil or gas sector operations in Venezuela, provided that performance of any such contract is expressly contingent upon a separate OFAC authorization.

This includes negotiations and contingent contracts involving the Government of Venezuela (GOV); Petróleos de Venezuela, S.A. (PdVSA); or any entity in which PdVSA owns, directly or indirectly, a 50-percent or greater interest (PdVSA Entities).

GL 49 includes the following as examples of authorized contingent contracts:

• Executory contracts
• Executory pro forma invoices
• Agreements in principle
• Executory offers capable of acceptance such as bids or proposals in response to public tenders
• Binding memoranda of understanding
• Any other similar agreement

OFAC further noted that GL 49 authorizes:

• Negotiating and entering into contingent contracts to engage in new oil or gas exploration, development, or production activities in Venezuela
• Expanding existing operations in Venezuela
• Forming new joint ventures or other entities in Venezuela related to the foregoing activities

GL 49 also authorizes preparatory steps to these activities such as conducting commercial, legal, technical, safety, and environmental due diligence and assessments.

However, GL 49 does not authorize:

• Any transaction involving a person located in Russia, Iran, North Korea, Cuba, or China or any entity that is owned or controlled by or in a joint venture with such persons
• The unblocking of any property blocked pursuant to the Venezuela Sanctions Regulations (VSR)
• Any transaction involving a blocked vessel

As noted above, a company seeking to rely on GL 49 must obtain specific OFAC authorization before performing under any contingent contract entered into pursuant to the license.

General License 50

GL 50 authorizes all transactions related to oil or gas sector operations in Venezuela with the entities listed in the Annex to GL 50 and their subsidiaries.

To rely on GL 50 for contracts with GOV, PdVSA, or PdVSA Entities, the contracts must specify that US laws govern and that contractual disputes must be resolved in a US forum.

In addition, GL 50 requires that any payment to a blocked person, excluding payments for local taxes, permits, or fees, must be made into Foreign Government Deposit Funds, as specified in Executive Order 14373, or any other account as instructed by the US Department of the Treasury. Such payment instructions also apply to any payments of oil or gas taxes or royalties to the GOV, PdVSA, or PdVSA Entities.

GL 50 further imposes detailed payment limitations. Payment terms must be commercially reasonable and cannot involve debt swaps or payments in gold or digital currency issued by or on behalf of the GOV, including the Petro, Venezuela’s state-backed cryptocurrency.

GL 50 does not authorize:

• Any transaction involving a person located in Russia, Iran, North Korea, Cuba, or China or any entity that is owned or controlled by or in a joint venture with such persons
• The unblocking of any property blocked pursuant to the VSR
• Any transaction involving a blocked vessel

An entity that relies on GL 50 must submit a detailed transaction report to the Department of State and Department of Energy within ten days of its first qualifying transaction and every 90 days thereafter. Such reports must include:

• A list of the parties involved
• A description of the transactions, including, as relevant, the quantities, values, and dates of the transactions
• A list of any taxes, fees, or other payments provided to GOV

Practical impacts

GL 49 and GL 50 authorize transactions and activities that complement those authorized by other recently issued GLs (GL 46A, GL 47, GL 48). For more information on these other GLs, please see our alert. Combined, the GLs create a series of authorization mechanisms that US entities can use when seeking to engage with or re-enter the Venezuelan oil and gas industry.

Conclusion

While GL 49 and GL 50 authorize numerous activities and transactions, the authorizations are limited in scope, have specific compliance requirements, and, in the case of GL 49, require further engagement with OFAC before performance can occur. In addition, nothing in GL 49 and GL 50 relieves any person from compliance with the requirements of other US federal agencies, such as the Department of Commerce’s Bureau of Industry and Security (BIS).

Learn more

DLA Piper continues to monitor developments in Venezuela and across the region and regularly advises companies on resulting compliance obligations. For more information on the implications of the GLs for your business and how DLA Piper can help determine the applicability of GLs in specific scenarios, please contact any of the authors.