Entities not identified in the Annex to GL 50A can rely on other authorizations to support the development of oil or gas projects in Venezuela. For example, such companies can enter into contingent contracts for new investments in the Venezuela oil or gas sectors pursuant to GL 49 and submit a specific license application to OFAC to request additional authorization to perform any contingent contracts executed.
Additionally, GL 48 authorizes, subject to certain restrictions, the provision of goods, technology, software, or services from the United States or by a U.S. person for the exploration, development, or production of oil or gas in Venezuela. Transactions authorized under GL 48 include activities in support of: (1) existing oil or gas operations in Venezuela, or (2) exploration or due diligence activities necessary to inform future joint ventures or other oil or gas developments, such as the importation of software to assist in conducting site surveys, data processing or modeling, or seismic or geologic studies, for example. For more information on what transactions are authorized and excluded by GL 48, see FAQ 1241.
Taken together, GLs 48 and 49 authorize all transactions otherwise prohibited by the Venezuela Sanctions Regulations (VSR) by interested parties to conduct all necessary due diligence activities—including the importation of goods, services, or technologies consistent with U.S. export control law—to inform the negotiation of and entry into contingent contracts for new investment in the oil or gas sector of Venezuela.
Alternatively, U.S. persons could also enter into contracts with entities identified in the Annex of GL 50A to support authorized activities in the Venezuelan oil or gas sectors. For more information on what transactions GL 50A authorizes, see FAQ 1242.