OFAC General License 41: Chevron's Venezuela license — the complete history

For 30 months between November 2022 and May 2025, the single most important document for Venezuelan oil production was a one-page general license issued by the US Department of the Treasury's Office of Foreign Assets Control. General License 41 authorized Chevron Corporation and its joint ventures with PDVSA to resume limited oil production and lifting in Venezuela — the first significant relaxation of the post-2019 oil-sector sanctions framework. By the time GL 41B wound it down to a May 27, 2025 expiration, the license had generated approximately 200 million barrels of crude oil, brought tens of billions of dollars of value through US Gulf Coast refineries, and reshaped Venezuelan oil production fundamentals.

This is the full history. It is the GL 41 chapter of the broader OFAC sanctions framework.

The pre-GL 41 baseline

To understand GL 41, you need to understand what came before. Sanctions on Venezuela's oil sector accumulated through four executive orders and dozens of OFAC actions between 2015 and 2019:

• Executive Order 13692 (2015): declared the situation in Venezuela a national emergency under IEEPA
• Executive Order 13808 (2017): prohibited new debt and equity dealings with the Government of Venezuela and PDVSA
• Executive Order 13850 (2018): blocked property of designated Venezuelan officials
• Executive Order 13884 (2019): comprehensive blocking of the Government of Venezuela; PDVSA designated as SDN on January 28, 2019

After the January 2019 PDVSA designation, US persons were essentially prohibited from any dealings with PDVSA. Chevron, ExxonMobil, ConocoPhillips, and other US oil majors had to wind down Venezuelan operations under OFAC-issued specific licenses. By 2022, Venezuelan oil production had collapsed from its 2010s peak of 2.4 million barrels per day to approximately 700,000 bpd, with much of the decline attributable to sanctions, mismanagement, and underinvestment.

GL 41 — the November 2022 issuance

On November 26, 2022, OFAC issued General License 41. It authorized Chevron Corporation and its US-incorporated joint ventures with PDVSA — specifically Petroboscan, Petroindependencia, Petropiar, and Petroindependiente — to engage in certain transactions related to oil-and-gas operations in Venezuela.

What GL 41 specifically authorized

• Production of crude oil and natural gas from the four named joint ventures' Venezuelan assets
• Repair and maintenance of associated facilities
• Limited transportation, storage, and marketing of oil produced
• Export of the oil specifically to the United States (Gulf Coast refineries)
• Purchase of inputs and services for the operations
• Payment of taxes, royalties, and operational costs to the Venezuelan government

What GL 41 explicitly did not authorize

• Export of oil to third-country buyers other than US
• Cash payments to PDVSA or the Venezuelan government beyond required operational costs
• New investments or capital injections beyond what was necessary to maintain authorized operations
• Transactions outside the named joint ventures
• Dealings with sanctioned Venezuelan officials in their individual capacities

The receivables mechanism

The key economic feature: GL 41 was structured so that the proceeds of the authorized oil exports would be applied to Chevron's substantial outstanding receivables from PDVSA — debts accumulated from years of operations under prior licensing periods. In other words, the oil exports paid down old debt rather than generating new cash payments to PDVSA. This structure was central to OFAC's framing of the license as not providing material new resources to the Venezuelan government.

By mid-2024 industry reporting indicated that Chevron's outstanding receivables had been substantially worked down, with the relationship moving from receivables-recovery toward more conventional ongoing payment structures.

Production volumes under GL 41

Period	Approximate JV production (bpd)	Direction
Q1 2023	~80,000-120,000	Initial ramp
Q2-Q3 2023	~120,000-180,000	Continued ramp
Q4 2023	~190,000-210,000	Stabilizing
2024 average	~200,000-250,000	Steady state, intermittent peaks
Q1 2025	Brief peaks above 300,000	Late maximum
April-May 2025 (wind-down)	Declining	Ramping to closure

Cumulative authorized production from the four JVs over the 30-month period: approximately 200 million barrels. The substantial majority went to US Gulf Coast refineries — primarily Phillips 66, PBF Energy, and Valero facilities equipped to process Venezuelan heavy crude.

GL 41 — the modifications

Continual sub-issuances and clarifications

Between November 2022 and March 2025, OFAC issued multiple amendments, FAQs, and clarifying guidance under the GL 41 umbrella. Topics covered: which specific transactions fell within "production and maintenance," how to handle taxes paid to Venezuelan agencies, transportation routing requirements, and reporting obligations to OFAC.

GL 41A — March 4, 2025

On March 4, 2025, OFAC issued General License 41A, which began the formal modification process. GL 41A maintained core authorizations but introduced new restrictions and reporting requirements signaling the policy shift to come.

GL 41B — March 24, 2025 — the wind-down

Twenty days later, on March 24, 2025, OFAC issued General License 41B, which replaced GL 41 and GL 41A with a wind-down authorization. GL 41B authorized Chevron and its joint ventures only to perform activities necessary to safely cease the operations previously authorized — completing in-progress lifts, paying out workforce obligations, closing contracts — by May 27, 2025. After May 27, the GL 41 framework was no longer available.

Policy reasoning for the wind-down

The official OFAC framing for the GL 41B wind-down cited the Venezuelan government's failure to meet specific democratic and electoral commitments under the prior diplomatic understanding. The November 2022 issuance had been linked, at least informally, to expected steps toward credible presidential elections in 2024. The 2024 election cycle did not produce outcomes the US treated as meeting that expectation, and the GL 41B wind-down followed.

Industry observers also noted broader sanctions policy reshaping during the same period including additional SDN designations against Venezuelan shadow-fleet operators and other actors. The GL 41B wind-down fit within that broader policy direction.

What came after GL 41

Post-May 2025, the OFAC Venezuela-oil framework has consisted of:

Specific licenses to individual operators

• Maurel et Prom (France): specific license authorizing limited production in Venezuela
• Repsol (Spain): specific license for ongoing operations
• ENI (Italy): specific license
• Reliance Industries (India): specific license
• Various smaller operators with bilaterally negotiated specific licenses

Continued GL framework for non-oil activities

• GL 3I — secondary-market trading of certain pre-existing Venezuelan and PDVSA debt
• GL 5R — PDVSA 2020 bond and related authorizations
• GL 7C, 8 series, 9H, 13 — various humanitarian, telecommunications, civil society, and operational authorizations
• GL 43, 44/44A, 45 — various specific transaction authorizations (note GL 44 expired April 18, 2024)

Chevron's continued status

After the GL 41B wind-down, Chevron's ongoing presence in Venezuela has been limited to the narrow scope authorized by other licenses, predominantly maintenance of its physical assets and personnel safety rather than active production. Specific operational arrangements have evolved through a sequence of OFAC actions; verify current status with primary sources.

The investor takeaway

For investors watching Venezuela exposure — distressed debt funds, oil-sector analysts, fund compliance teams — the GL 41 history offers several lessons:

• OFAC general licenses are policy instruments, not entitlements. They can be modified, restricted, or wound down with relatively short notice.
• The receivables-recovery structure was a deliberate policy choice to thread the needle between operational pragmatism and sanctions integrity.
• Even at peak production under GL 41, Venezuelan oil production remained far below pre-sanctions capacity (~700K-1M bpd total vs 2.4M bpd historic peak), demonstrating the durability of underinvestment effects.
• The specific-license framework that has succeeded the GL 41 framework is more bespoke, slower, and more narrowly applicable.
• Continued OFAC engagement is required for any institutional Venezuela exposure.

For broader institutional positioning around Venezuelan oil-sector exposure, see our Venezuela oil for foreign investors guide and our PDVSA bonds 2026 outlook.