OFAC Redefines Venezuelan Oil Trade: Financial Control, Geopolitical Exclusions, and a Market Conditioned by Washington
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury updated the operational scope of General License 46 (GL 46) on February 6, 2026. This key instrument regulates the trade of Venezuelan oil under sanctions. The new clarifications do not lift the structural restrictions against the energy sector but do establish a strictly monitored legal channel for Venezuelan crude to circulate in the global market.
The framework is clear: oil can be sold, transported, and refined, but only under conditions set by Washington and executed within the U.S. legal system.
The license authorizes activities related to the purchase, export, transport, storage, marketing, and resale of Venezuelan-origin oil, provided they are executed by an “established U.S. company,” meaning a firm organized under U.S. laws before January 29, 2025. The scope includes commercial negotiations, technical inspections, maritime logistics, shipment financing, insurance, and maintenance of the necessary infrastructure for loading and exporting crude.
However, the permit does not imply a reopening of the Venezuelan oil sector. OFAC emphasizes that the license does not authorize exploration, drilling, or investments to develop oil fields. Nor does it allow negotiations aimed at concessions or structural participation in the industry. The message is clear: trading is allowed with already produced oil, not reconstructing the country’s productive capacity.
One of the most significant elements of the new framework is the explicit exclusion of geopolitical actors considered strategic adversaries. GL 46 prohibits the participation of individuals or entities linked to Russia, Iran, North Korea, and Cuba, as well as companies controlled by these countries. Additionally, it restricts operations with Venezuelan or U.S. companies under direct control or association with Chinese capital.
However, the regulation introduces a critical distinction. While it limits Chinese participation in the initial phase of transactions, it does allow Venezuelan oil to be resold to China in the global market, provided the primary operation was performed by an authorized U.S. company. In practical terms, Washington controls the entry point into the business but not necessarily its final destination.
The license also establishes strict financial conditions. All operations must be conducted under “commercially reasonable terms,” meaning in line with international market standards regarding price, quality, volume, and contractual security. Payments in gold, the use of cryptocurrencies or state tokens like the petro, debt swaps, and any transactions involving vessels blocked by sanctions are prohibited.
Once the initial transaction is completed according to the license and the involvement of sanctioned entities has ceased, the oil can be sold, resold, and traded freely by subsequent buyers, even if they are not U.S. companies. This element creates a global downstream circuit where control is mainly exercised in the initial phase of the operation.
OFAC also gives banks, insurers, and logistics providers a relevant role. Financial institutions can validate operations based on client declarations, unless there are signs of irregularities. At the same time, non-U.S. companies can participate by offering transportation, marine insurance, storage, financing, and technical maintenance, creating an international network around the authorized trade.
The definition of “Venezuelan-origin oil” is expanded to include not just crude, but also refined fuels, asphalt, petroleum coke, heavy blends, and byproducts derived from refining. The commercial scope is broad, but regulatory control remains strict.
Beyond technical language, the architecture of General License 46 reveals an energy and geopolitical strategy. Washington does not eliminate sanctions or fully normalize the Venezuelan oil sector; it establishes a mechanism that allows for the flow of crude under U.S. legal and financial supervision, limits the influence of adversarial actors, and maintains control over the first phase of transactions.
The result is a hybrid model: Venezuela can sell oil, but within a system where the rules, financial validation, and checkpoints are concentrated outside the country. The crude returns to the international market, but does so under a structure designed to ensure that the energy business passes through the filter of U.S. foreign policy and security.