US Treasury issues Venezuela general licenses related to contingent contract negotiations with the Government of Venezuela and financial services

On April 14, 2026, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two general licenses that expand the scope of authorized activities involving the Government of Venezuela (GoV) and certain Venezuelan financial institutions.

Venezuela General License 56 (GL 56) authorizes all transactions ordinarily incident and necessary to commercial contract negotiations with the GoV, provided that the entry into and performance of any such contract is expressly contingent on obtaining separate authorization from OFAC (i.e., a contingent contract).

Venezuela General License 57 (GL 57) authorizes the provision and receipt of certain financial services to or from 1) specified Venezuelan financial institutions and their subsidiaries and 2) certain individuals blocked solely due to their GoV status.

These authorizations build on prior Venezuela GLs described in recent DLA Piper alerts, specifically those addressing OFAC GLs 49 and 50 and GL 52.

This alert summarizes GLs 56 and 57 and highlights key considerations for US and non-US companies that may be evaluating Venezuela-related opportunities in light of these authorizations.

Key takeaways

For persons subject to US jurisdiction, GL 56 provides a limited pathway to engage in “commercial-related negotiations” with the GoV[1] and GoV-owned or -controlled entities. According to GL 56, before performing on any contract with the GoV, a US person must seek a specific license from OFAC to enter into and perform any resulting agreement. To seek a specific license, the US person must submit detailed information to OFAC about their proposed activities with the GoV. OFAC, along with the State Department, will then assess whether granting such a license is consistent with US foreign policy goals in Venezuela.

GL 57 separately authorizes certain financial services involving specified Venezuelan banks and certain GoV employees blocked solely due to their relationships with the GoV, subject to significant exclusions and limitations. This authorization substantially facilitates financial transactions between the US and Venezuela and, in particular, with the GoV and related entities.

Unlike other recently issued general licenses related to Venezuela, GLs 56 and 57 do not specify their application to established US entities, or entities organized under the laws of the US or any jurisdiction within the US, on or before January 29, 2025. However, Executive Order (EO) 13884, “Blocking Property of the Government of Venezuela,” carries a material support sanctions authority for non-US persons that materially assist, sponsor, or provide financial, material, or technological support for, or goods or services to or in support of, entities designated pursuant to said EO.

General License 56

GL 56 authorizes all transactions prohibited by EO 13884 that are ordinarily incident and necessary to commercial-related negotiations of contingent contracts with the GoV.

GL 56 defines “contingent contracts” to include 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, and similar agreements. Further, GL 56 authorizes transactions ordinarily incident and necessary to commercially related negotiations of such contingent contracts, provided that the entry into and performance of any such contracts are expressly contingent on obtaining separate authorization from OFAC.

GL 56 does not address when parties should submit a specific license application to enter into and perform a negotiated contingent contract. As a practical matter, OFAC typically requires sufficient detail, including the parties, scope of work, and payment terms, in order to evaluate the contemplated activity. OFAC also may request copies of relevant transaction documents. Companies are therefore encouraged to consider the sequencing of negotiations, document finalization, and licensing strategy early in the process – particularly where commercial terms may evolve materially over time.

GL 56 underscores the US government’s continued emphasis on retaining licensing control over US commercial engagement with the GoV by permitting negotiations while expressly conditioning any entry into and performance of the negotiated agreement on the issuance of an OFAC-specific license. OFAC’s specific licensing review will likely focus on the contemplated counterparties, scope of work, payment terms, the extent to which the proposed transaction implicates expressly excluded activity, and the extent to which the proposed transaction is consistent with US foreign policy objectives.

GL 56 also may be read in light of OFAC’s broader approach in recent Venezuela-related general licenses, which have included express exclusions for certain categories of transactions (including, in several instances, transactions involving digital or virtual currency). Against that backdrop, companies negotiating with GoV counterparties are encouraged to evaluate at the term-sheet stage whether the contemplated activity is likely to fall within an excluded category or otherwise structure the transaction with the aim of a favorable licensing review.

GL 56 does not authorize the following categories of activity, among others:

• Transactions restricted under the Venezuela Sanctions Regulations (VSR) or other Venezuela-related authorities: Transactions otherwise prohibited by the VSR (31 C.F.R. Part 591), including transactions prohibited by EO 13808, “Imposing Additional Sanctions with Respect to the Situation in Venezuela,” related to bonds and certain other debt of the GoV or PdVSA, including transactions to settle such bonds and debt
  
  
• Payment terms and consideration: Payment terms that are not commercially reasonable or that involve debt swaps, payments in gold, or transactions denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the GoV (including the Petro)
  
  
• Enforcement and blocked property: Entry into a settlement agreement or enforcement of any lien, judgment, arbitral award, decree, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property blocked pursuant to the VSR
  
  
• Sanctioned country nexus: Any transaction involving 1) a person located in or organized under the laws of Russia, Iran, North Korea, or Cuba or 2) any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons
  
  
• China nexus: Any transaction involving an entity located in or organized under the laws of Venezuela or the US that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of China
  
  
• Entities on the Specially Designated Nationals and Blocked Persons List (SDN List): Any transaction involving an individual or entity on the SDN List not captured by the GL, as well as any entity in which one or more SDNs own, directly or indirectly, individually or in the aggregate, a 50-percent or greater interest
  
  
• Unblocking: The unblocking of any property blocked pursuant to OFAC sanctions programs

General License 57

GL 57 authorizes the provision and receipt of financial services to or from certain blocked Venezuelan banks and their subsidiaries, including:

• Banco Central de Venezuela
• Banco de Venezuela
• Banco Digital de los Trabajadores
• Banco del Tesoro

GL 57 also expressly authorizes certain GoV employees who are blocked solely due to their status as GoV employees to benefit from the exportation of US financial services. Notably, GL 57 does not authorize the unblocking of any property or interests in property that have previously been blocked.

The definition of "financial services" encompasses account operations, lending transactions, funds transfers, money transfers, deposits, withdrawals insurance, digital wallets, mobile money, investments, securities, and commodity futures or options. GL 57 also states that a US financial institution that processes any such transactions may rely on representations from the originator or beneficiary of a funds transfer “provided that the processing financial institution does not know or have reason to know that the transaction is not in compliance with” GL 57.

While the covered Venezuelan banks remain blocked – either because they are identified on the SDN List or are blocked by operation of law – GL 57 may allow US financial institutions and other US persons to process certain transactions to, from, or involving these institutions, subject to the general license’s conditions, exclusions, and limitations.

GL 57 does not authorize transactions otherwise prohibited by the VSR unless separately authorized, and it does not authorize the unblocking of any property blocked pursuant to any OFAC sanctions program.

Conclusion

DLA Piper continues to monitor developments in Venezuela and across Latin America and regularly advises companies on resulting sanctions and compliance obligations. For more information on GLs 56 and 57 and their potential impact on your organization, please contact any of the authors.

 

^{[1] For purposes of EO 13884 and the Venezuela Sanctions Regulations, 31 C.F.R. part 591, the “Government of Venezuela” is defined broadly and includes political subdivisions, agencies, and instrumentalities of the state, as well as entities that are owned or controlled, directly or indirectly, 50 percent or more by the GoV. In practice, this definition can capture a wide range of counterparties in Venezuela, including dealings with the country’s state-owned entities.}