• On January 29, 2026, OFAC issued General License 46, authorizing certain activities involving Venezuelan-origin oil by established U.S. entities, subject to strict and detailed conditions.
• The license does not dismantle or suspend the Venezuela sanctions regime; it operates as a narrow, conditional authorization within it.
• The greatest risk lies not in the absence of a license, but in misapplying it—assuming coverage without verifying that every operational, contractual, and payment condition is met.
