On March 18, 2026, the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC”) issued General License 52 (“GL52”), authorizing certain transactions involving Petroleos de Venezuela, S.A. (“PdVSA”).
GL 52 authorizes certain transactions involving PdVSA and entities in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, provided that such transactions are conducted by “established U.S. entities” and comply with specific conditions. These conditions include, among others, (i) requiring that contracts be governed by U.S. law and provide for a dispute resolution in the U.S.; and (ii) requiring that any payments to blocked persons (other than certain local taxes or fees) be made into designated Foreign Government Deposit Funds or other accounts as instructed by the U.S. Department of Treasury.
