Overview
- OFAC on February 10 issued GL 48, GL 46A, and GL 30B to widen authorized activity connected to Venezuelan oil and critical operations.
- GL 48 permits U.S. persons to provide goods, technology, software, and services for exploration, development, and production to PDVSA and majority-owned affiliates under GL 46–style guardrails.
- Compliance terms require U.S.-law contracts with U.S. dispute resolution, payments to blocked persons routed to the Foreign Government Deposits Fund except for local taxes or fees, and reporting to State and DOE.
- Prohibitions include commercially unreasonable terms, debt swaps, gold or specified digital currencies, dealings with Russia, Iran, North Korea, Cuba, or China, unblocking of property, new joint ventures, and any diluent exports or reexports.
- New FAQs clarify downstream trading once blocked interests are extinguished, define the scope for non-U.S. ancillary participation, outline bank reliance on customer attestations, and explain the dispute-resolution requirement.