OFAC Venezuela sanctions in 2026: The current General License framework

The US sanctions program on Venezuela is one of the more complex active sanctions regimes in the world. It involves four overlapping executive orders, a long list of General Licenses (GLs) that have been issued, modified, replaced, and wound down across nearly a decade, a constantly-shifting SDN list, and a 50% ownership rule that pulls hundreds of state-owned subsidiaries into the blocking net without ever naming them explicitly. For a compliance officer at a fund, bank, or counterparty considering Venezuelan exposure, the relevant question is rarely “are there sanctions?” The answer to that is always yes. The relevant questions are: what is actually blocked, what is licensed today, and how stable is the license likely to be for the duration of my transaction?

This article maps the framework as it stands in May 2026. The legal landscape is dynamic — General Licenses can be replaced or wound down with a few business days' notice — so every transaction-level decision needs a current OFAC.treasury.gov check and licensed counsel. What follows is the structure, not the day's headlines.

The four foundational executive orders

Venezuela sanctions sit on four stacked Executive Orders, each one expanding the authorities of the prior. None has been rescinded. The current framework remains all four together, codified in the Venezuela Sanctions Regulations at 31 CFR Part 591.

Executive Order	Date	What it authorizes
EO 13692	March 8, 2015 (Obama)	Initial Venezuela sanctions authority targeting human-rights actors
EO 13808	August 24, 2017	Barred US persons from dealing in new Venezuelan government and PDVSA debt; the first sectoral sanction
EO 13850	November 1, 2018	Sanctions authority over Venezuela's gold sector; used to designate Minerven
EO 13884	August 5, 2019	Blocking sanctions on the Government of Venezuela; the comprehensive blocking authority

EO 13884 is the most consequential because it broadened the “Government of Venezuela” definition to include all political subdivisions, agencies, and instrumentalities — PDVSA, the central bank (Banco Central de Venezuela), and any entity owned or controlled by the regime. Combined with the SDN designation of PDVSA on January 28, 2019 (under EO 13850 authority), the practical effect is that any US person dealing with the Venezuelan state sector requires either a General License or a specific license.

The General License stack — what's authorized today

The General Licenses are how OFAC carves out specific authorized activities from the blanket prohibition. Some are narrow (one company's wind-down). Some are broad (an entire commercial sector). The active stack as of May 2026, drawing from OFAC and Federal Register publications:

GL family	What it authorizes	Status (May 2026)
GL 3 series (latest GL 3I)	US-person trading in specified Government of Venezuela sovereign bonds (Annex list) on or after Oct 18, 2023, including divestment to other US persons	Active — opened the secondary trading window for defaulted Venezuelan debt
GL 5 series (latest GL 5R)	PDVSA 2020 Bondholders' authorization to take steps related to the Citgo Holding share collateral after a moving “no-earlier-than” date	Active — extended via Federal Register publication July 23, 2025
GL 7 series (latest GL 7C)	PDV Holding, Citgo Holding, and Citgo Petroleum authorized to operate independently of PDVSA	Active — renewed on rolling basis
GL 8 series (oilfield services)	Halliburton, Schlumberger/SLB, Baker Hughes, Weatherford International limited maintenance operations in Venezuela	Largely wound down post-2024; subsequent activity under specific licenses
GL 9H	US-person dealings in PDVSA 2020 8.5% Bonds on or after January 18, 2024	Active — enabled secondary trading in the secured PDVSA paper
GL 13 series	Nynas AB (Swedish PDVSA subsidiary) wind-down/operations	Active (sector-specific)
GL 41B	Chevron wind-down through May 27, 2025	Expired May 27, 2025 — Chevron activity now under specific license
GL 43	Minerven (gold sector) wind-down following the October 2023 Barbados Agreement	Active or wound-down by year-end 2024 depending on transaction
GL 44 / GL 44A	Oil-and-gas sector broad authorization (issued Oct 18, 2023 with Barbados Agreement)	Expired April 18, 2024; GL 44A issued same day for 45-day wind-down
GL 45	Companies Bank account services	Active per current OFAC publications

The pattern is clear: General Licenses are the steering wheel of Venezuela sanctions. Treasury uses them to dial enforcement up or down without amending the underlying executive orders. The October 2023 Barbados Agreement — which produced a flurry of broad new GLs (3I, 5M, 9H, 43, 44, 45) on a single day — was the high point of sanctions relief. The April 2024 snapback (GL 44 expiration) marked the swing back toward enforcement. The 2025 GL 41 wind-down represented further tightening of the Chevron-specific carve-out.

The PDVSA 2020 Bond and the GL 5 series

Of the active GLs, the GL 5 series deserves particular attention because it relates to the only US-court-justiciable secured claim against PDVSA: the 2020 8.5% bonds collateralized by 50.1% of Citgo Holding shares. The structure was created in a 2016 distressed exchange when PDVSA offered holders of its April and November 2017 notes the option to swap into a new note maturing October 27, 2020, secured by the Citgo equity pledge.

GL 5 has been extended repeatedly to push back the “no-earlier-than” date on which US-person creditors could take steps against the collateral. The most recent extension, GL 5R, was published in the Federal Register on July 23, 2025 (Federal Register 2025-13846). The legal validity of the underlying bonds was confirmed in Petróleos de Venezuela, S.A. v. MUFG Union Bank, N.A. when Judge Katherine Polk Failla of the Southern District of New York granted summary judgment for the bondholders on September 18, 2025 — holding that Venezuelan law governed validity and rejecting the act-of-state defense based on the 2016 National Assembly resolutions. The Citgo auction TSA settling these bonds at $2.125 billion now sits inside the Amber Energy / Elliott bid approved by Judge Stark on November 29, 2025.

See our deep-dive on PDVSA bonds in 2026 for the full restructuring picture, and on Citgo Petroleum's legal future for the auction mechanics.

The GL 41 wind-down — what just happened to Chevron

GL 41, originally issued November 26, 2022 (Treasury press release JY1127), authorized Chevron Corporation and its named JVs — Petroboscán, Petropiar, Petroindependencia, and Petroindependiente — to engage in production, sale, exportation, and related activities involving PDVSA-owned joint ventures. The key constraints: no cash payments could accrue to PDVSA or the Government of Venezuela in the form of taxes, royalties, or dividends; transactions had to be structured as oil-for-debt, offsetting Chevron's outstanding PDVSA receivables.

Under GL 41, Chevron-operated JV output rose from roughly 50,000 barrels per day at the end of 2022 to approximately 200,000 b/d by 2025. On March 4, 2025 (recent OFAC action 20250304), OFAC issued GL 41A replacing GL 41 with a 30-day wind-down ending 12:01 a.m. EDT April 3, 2025. On March 24, 2025, GL 41B extended the wind-down to 12:01 a.m. EDT May 27, 2025, and added a new Note 2 explicitly prohibiting expansion of the Chevron JVs into new fields in Venezuela.

After May 27, 2025, all Chevron transactions in Venezuela require specific licenses issued on a case-by-case basis. The same model now governs activity by Maurel et Prom (France), Repsol (Spain), and ENI (Italy) — each of which holds non-public specific licenses for their respective Venezuelan JVs. The broad sector-wide authorization of the 2022-2023 period is over. Foreign oil-sector activity in Venezuela in 2026 happens under bespoke OFAC letters, not GLs.

For the deeper Chevron-specific picture, see our GL 41 explainer.

The 50% Rule — the hidden expansion of the SDN list

Perhaps the single most important compliance concept for Venezuela exposure is OFAC's 50% Rule. The rule, stated in OFAC's August 13, 2014 general guidance and confirmed in FAQ topic 1581 (and FAQ 401 and 416 for Venezuela context), provides:

Any entity owned 50% or more, directly or indirectly, individually or in the aggregate, by one or more blocked persons is itself blocked — even if not separately named on the SDN list.

Because PDVSA, the Government of Venezuela (broadly defined), and the named individual SDNs (Maduro, military officials, judicial officials, intelligence service heads) are all blocked, their majority-owned subsidiaries are automatically blocked. In the Venezuelan state-sector context, this captures dozens of state companies, special-purpose vehicles, and offshore subsidiaries that never appear on the SDN list by name. A counterparty due-diligence process that only screens against the published SDN list will miss them.

The practical takeaway: serious Venezuela exposure requires beneficial-ownership tracing, not just name screening. Compliance teams typically use a layered process — OFAC SDN screen plus a third-party beneficial-ownership database (Refinitiv World-Check, Sayari, Dow Jones) plus internal escalation for any entity with state-sector linkage.

SDN list — the named individuals and entities

Beyond the structural blocking under EO 13884, Treasury has named many specific Venezuelan individuals and entities to the SDN list under EOs 13692 and successor authorities. The list includes:

• Nicolás Maduro Moros — SDN since July 31, 2017 (EO 13692)
• Senior officials including Diosdado Cabello, Tareck El Aissami, Vladimir Padrino López (defense minister), Néstor Reverol, Maikel Moreno, Tarek William Saab (attorney general), Iris Varela, and Cilia Flores
• Family members of designated officials, including Maduro's wife and sons
• Military and intelligence officers across SEBIN and DGCIM
• Designated members of the Maduro-aligned Supreme Tribunal of Justice
• Various PDVSA officials and oil-sector traders linked to sanctions evasion

The list is updated periodically. The most recent significant tranche, announced December 19, 2025 (Treasury press release SB-0348), added Maduro-affiliated oil traders and four vessels described as part of the “shadow fleet” transporting Venezuelan oil in evasion of sanctions. See our SDN compliance guide for the full screening workflow.

Compliance reality for funds and banks

For institutional counterparties — hedge funds, distressed-debt shops, banks providing correspondent services, brokers settling Venezuelan bond trades — the Venezuela sanctions regime imposes a layered compliance burden that has been refined through a decade of OFAC guidance and enforcement.

The OFAC Framework for OFAC Compliance Commitments, published May 2019, identifies five essential components: management commitment, risk assessment, internal controls, testing and auditing, and training. Venezuela-specific risks that map to these components in 2026:

• Indirect counterparty exposure through Russian, Iranian, Turkish, Indian, and Chinese intermediaries — common in oil-trading routes and increasingly in bond settlement.
• Vessel and tanker screening — the December 2025 shadow-fleet designations made clear that OFAC is actively tracing vessel movements through ship-tracking data; AIS spoofing patterns are now part of standard screening.
• Correspondent banking with Venezuelan state banks — historically high-risk; the named state banks remain subject to varying restrictions and require careful GL or specific-license analysis.
• Bond settlement chains — secondary trading in Annex-listed sovereign bonds is permitted under GL 3I and PDVSA 2020s under GL 9H, but the chain of custody from prior holder to current US-person buyer must be checked for SDN linkage.
• Beneficial-ownership tracing on any Venezuelan corporate counterparty — 50% Rule application.

Civil penalty exposure under IEEPA remains substantial: the maximum civil penalty per violation, inflation-adjusted, sits around $375,000 (or twice the transaction value, whichever is greater). Criminal violations carry up to $1 million in fines and 20 years' imprisonment. Recent enforcement actions affecting Venezuela include Société Générale's $1.34 billion combined DOJ/OFAC settlement in November 2018 covering Cuba/Iran/Venezuela-related transactions — a reminder that historical patterns of evasion-structure facilitation can produce nine-figure liability years after the fact.

Where the framework goes next

Predicting OFAC policy shifts is a fool's errand. What we can say from the publicly available record: General Licenses are the lever Treasury reaches for first when conditions change, and the GLs already on the books leave both directions open. A re-easing scenario could restore something like the post-Barbados GL 44 framework or extend it further; a tightening scenario could narrow the secondary-trading windows currently keeping the bond market liquid. The mid-2025 GL 41 wind-down established that Treasury is comfortable rolling back specific authorizations on short notice. The October 2023 Barbados Agreement-linked GLs established that Treasury is equally comfortable opening up new ones when diplomatic conditions warrant.

For institutional investors, the practical implication is to size positions and structure transactions assuming both directions remain in play. The defaulted sovereign and PDVSA debt that traded at six to twelve cents in 2022 reached 27-43 cents in 2025 in part on sanctions-easing optimism. Whether the 2026 trajectory consolidates those gains or partially retraces depends entirely on what OFAC and the Federal Register publish next, not on the framework already in place.