OFAC Issues General License 52 Authorizing Certain Transactions Involving PdVSA

Overview

On March 18, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Venezuela‑related General License 52 (“GL 52”), Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A. (“PdVSA”). GL 52 reflects a continuation of OFAC’s broader shift toward facilitating tightly controlled commercial re‑engagement with Venezuela following recent geopolitical developments. Accompanying the license, OFAC also issued FAQ 1245 and FAQ 1246, which provide important clarification concerning both the scope of the authorized activities and key restrictions that remain in place.

Scope and Conditions of Authorized Activities

GL 52 authorizes all transactions otherwise prohibited by Executive Orders 13884 and 13850 when they involve PdVSA or entities in which PdVSA directly or indirectly holds a fifty % or greater interest, provided they are conducted by an “established U.S. entity.” As noted under previous licenses, an established U.S. entity