OFAC Amends Eight Venezuela General Licenses, Easing Contract Choice-of-Law Requirements

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) amended eight Venezuela-related general licenses on 27 August 2026, revising the contractual conditions attached to authorised activity across oil, petrochemicals, diluents, minerals, gold, telecommunications and transactions involving Petróleos de Venezuela, S.A. (PdVSA).

The amended measures are General Licenses 46D, 47B, 48C, 50C, 51C, 52B, 54B and 61A. Together, they cover activities including dealings in Venezuelan-origin oil or petrochemical products, sales of U.S.-origin diluents, supply of specified goods and services, certain oil and gas operations, minerals including gold, transactions involving PdVSA and telecommunications-related activity.

Choice-of-law requirement removed

OFAC’s new FAQ 1267 clarifies that, effective 27 August, contracts authorised under the relevant general licenses with the Government of Venezuela or specified blocked persons no longer need to state that the contract is governed by the law of a U.S. state or other U.S. jurisdiction. OFAC said it removed that requirement in response to investment-related reforms undertaken by the Venezuelan government since January 2026.

The change does not remove the separate dispute-resolution requirement. FAQ 1268 states that qualifying contracts must still provide for dispute-resolution proceedings to take place in the United States, United Kingdom, France or Singapore. OFAC also updated FAQs 1233 and 1244 and archived FAQ 1260 as part of the same action.

Relief remains activity-specific

The amendments do not amount to a general lifting of U.S. sanctions on Venezuela. Each general license continues to define the transactions, counterparties and conditions it authorises, while dealings outside those authorisations may remain prohibited. The affected licenses include transactions involving blocked entities such as PdVSA under GL 52B and CVG Compañía General de Minería de Venezuela CA under GL 51C.

For sanctions teams, the immediate operational issue is therefore contractual rather than a wholesale change in screening. Institutions and businesses relying on the amended licenses should update legal and compliance templates to remove obsolete U.S. choice-of-law assumptions while preserving the required dispute-resolution venue and checking the specific conditions of the license supporting each transaction.