PARTIAL SUSPENSION OF ECONOMIC SANCTIONS IN THE VENEZUELAN OIL SECTOR

Within the framework of the still-effective Venezuela Sanctions Regulations, contained in Title 31 of the Code of Federal Regulations, Subtitle B, Chapter V, Part 591 (Venezuela Sanctions Regulations – VSR), as well as the still-effective Executive Order 13850 and the January 28, 2019 Determination, which prohibit operating in Venezuela’s oil sector, since January 29, 2026, the Office of Foreign Assets Control (“OFAC”) has been issuing a series of General Licenses authorizing, under specific conditions, certain transactions related to oil and gas sector operations in Venezuela.

Previously, in earlier special bulletins, General Licenses 46 and 47 were summarized as the first licenses issued by OFAC authorizing the commercialization of Venezuelan-origin crude oil already extracted and the exportation of diluents to Venezuela. Likewise, recaps were provided of additional licenses issued (5U, 30B, 46A, 48, 49, and 50), which expanded the partial suspension of sanctions to production activities, as well as certain transactions related to new investments and broader authorization to operate in the Venezuelan oil sector for specific operators such as BP, Chevron, Eni, Repsol, and Shell.

Thus, pending further parameters and clarifications, as of yesterday, two Frequently Asked Questions (FAQs) were published, as well as a new license which includes an additional operator on the list, namely Établissements Maurel & Prom SA.

GENERAL LICENSE 50A

OFAC authorized the oil companies BP, Chevron, Eni, Établissements Maurel & Prom SA, Repsol, and Shell to operate in the Venezuelan oil sector.

On February 18, 2026, OFAC issued General License 50A (“GL 50A”), which fully replaces General License 50 (“GL 50”), authorizing BP PLC, Chevron Corporation, Eni S.p.A., Établissements Maurel & Prom SA, Repsol S.A., and Shell PLC, and their subsidiaries, to engage in all transactions related to operations in the oil or gas sector in Venezuela, including those 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.

The authorization is subject to:

The condition that monetary payments to a blocked person be made through the Foreign Government Deposit Fund (FGDF), excluding payments of local taxes, permits, or administrative fees; and

The obligation to submit transaction reports.

Reports must comply with OFAC’s record production and data submission requirements.

OFAC may require that such reports include the submission of books, contracts, letters, papers, or other printed or electronic documents related to any transaction.

REGARDING THE FAQs

FAQ No. 1236

How does General License 30B (“GL 30B”) differ from General License 30A (“GL 30A”)?

On February 10, 2026, OFAC issued GL 30B, which removes the prohibition established in GL 30A with respect to transactions or activities related to the exportation or reexportation of diluents to Venezuela.

Accordingly, transactions now authorized under GL 30B continue to include payments that are ordinarily incident and necessary to operations or to the use of ports and airports in Venezuela, including transactions involving the National Institute of Aquatic Spaces (INEA) or its majority-owned subsidiaries.

GL 30B authorizes the payment of port fees and customs duties, including activities authorized under GL 46A, GL 47, and GL 48.

FAQ No. 1237

Do General Licenses 46A (“GL 46A”) and 48 (“GL 48”) permit payments of certain taxes, permits, and local fees in support of authorized transactions involving Venezuela’s oil and gas sectors?

Yes. Pursuant to GL 46A and GL 48, routine payments of taxes, permits, and local fees to the Government of Venezuela (GOV) or its agencies are authorized.

However, other payments—such as royalties, fixed production levies per barrel, or federal taxes owed to blocked persons such as the GOV or PDVSA—must be made into the Foreign Government Deposit Fund, as specified in Executive Order No. 14,373, or into any other account designated by the U.S. Department of the Treasury.

Overview of the General Licenses Referenced in the FAQs

GENERAL LICENSE 30B:

Removes the prohibition on entering into transactions related to port and airport operations for the exportation of diluents to Venezuela.

GENERAL LICENSE 46A:

Excludes local taxes, permits, or administrative fees from the obligation of payment through the FGDF.

GENERAL LICENSE 47:

Authorizes the export, reexport, sale, supply, delivery, and transportation of U.S.-origin diluents to Venezuela.

GENERAL LICENSE 48:

Issues new authorization for the supply of certain goods and services for the exploration, development, or production of oil or gas in Venezuela.

Should you have any questions or require further clarification regarding the foregoing report, please do not hesitate to contact us.