Yes. Once a transaction with the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (PdVSA), or its majority-owned subsidiaries (PdVSA Entities) has been completed pursuant to GL 46, and the interest—including any future or contingent interest—of a blocked entity is fully extinguished, then the oil can be freely sold, resold, and traded by any downstream purchaser, including entities that are not established U.S. entities, as defined in GL 46.

In connection with its normal due diligence, a financial institution may rely on the statements of its customer that the transaction is consistent with the terms of GL 46, unless it knows or has reason to know otherwise.

No. The dispute resolution requirement in paragraph (a)(1) of GL 46 applies only to contracts governing transactions undertaken by an established U.S. entity when the contract is with the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (PdVSA Entities).

This requirement does not apply to indirect parties or indirect counterparties involved in transactions authorized by GL 46, such as downstream transactions involving the provision of shipping, insurance, or other services to an entity engaged in a transaction involving PdVSA. For example, this provision would not apply to a contract between an insurance provider and an established U.S. entity engaged in a transaction with PdVSA to purchase Venezuelan-origin oil (though it would apply to the contract between the U.S. entity and PdVSA).

"Commercially reasonable terms" means terms that are consistent with prevailing market and industry standards for like or similar products produced by a company of similar size and scope, while taking into account characteristics such as quality, quantity, pricing, performance, and safety, among others. Commercially reasonable terms include terms related to, among other things, the governance, economics, operations, and legal/compliance requirements of a contract negotiated at arm’s length between two or more parties.

GL 46 excludes the involvement of persons located in or organized under the laws of the Russia Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, and the Republic of Cuba—as well as any entity owned or controlled, directly or indirectly (including by or in a joint venture with) any of the foregoing.

In addition, GL 46 does not authorize transactions with any Venezuelan or U.S. entity that is owned or controlled by, or in a joint venture with, a person located in or organized under the laws of the People's Republic of China. However, GL 46 does not restrict the resale of Venezuelan-origin oil to China by an established U.S. entity.

Yes. Non-U.S. persons may engage in transactions or provide services that are ordinarily incident and necessary to the established U.S. entity’s transactions authorized by GL 46. Such activities or ancillary services could include: providing transportation and logistics services to an established U.S. entity for the export of Venezuelan-origin oil; providing marine insurance to vessels chartered by established U.S. entities to transport Venezuelan-origin oil; the financing of related cargoes or receivables; leasing storage facilities for Venezuelan-origin oil purchased by an established U.S. entity; or contracting with established U.S. entities for repair or maintenance services of infrastructure necessary to effectuate the export of oil from Venezuela, among others.

Please see FAQ 1235 for additional information regarding authorized downstream trading activities.

Please see FAQ 1231 for certain individuals and jurisdictions excluded from the scope of GL 46.

For purposes of GL 46, the term "established U.S. entity" means any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.

GL 46 is designed to help ensure that the oil exported from Venezuela will be through legitimate and authorized channels, consistent with U.S. law and President Trump's efforts to restore prosperity, safety, and security to the United States and Venezuela. Established U.S. companies should be familiar with complying with U.S. laws and regulations, including U.S. sanctions regulations, which will help ensure their ability to market Venezuelan oil in the global marketplace for the benefit of the United States, Venezuela, and our allies.

No. GL 46 authorizes the purchase, exportation, and sale of Venezuelan-origin oil that has already been extracted, including the refining of such oil. It does not authorize other exploration or production activities, such as conducting geological surveys, drilling wells, or extracting oil from fields in Venezuela, nor does it authorize activities related to investment in the Venezuelan oil sector, such as negotiations with Petróleos de Venezuela, S.A. (PdVSA) to enter into a contract to develop or operate oil fields, blocks, or other concessions. For more information on what transactions are authorized by GL 46, see FAQ 1227.

GL 46 authorizes activities that are ordinarily incident and necessary to the lifting (which refers to the physical loading and removal of oil from a terminal, storage facility, or production site for delivery to a buyer), exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil by an established U.S. entity, which may include:

• engaging in commercial, legal, and technical discussions necessary to scope purchases of Venezuelan-origin oil, including with third-party legal, commercial, or due diligence consultants;
• conducting safety, environmental, and other relevant inspections, including site surveys;
• arranging logistics, security services, delivery points, and shipping preparation, including obtaining marine insurance and engaging with relevant port or maritime authorities of the Government of Venezuela (GOV) or their personnel;
• conducting certain downstream activities, including the refining and resale of Venezuelan-origin oil;
• coordinating payment structures, including payments in the form of swaps of oil, diluents, or refined petroleum products, among others;
• making required repairs and maintenance to pipeline, storage, or port infrastructure necessary to effectuate the loading of vessels; or
• the financing of related cargos or receivables.

Notably, GL 46 does not authorize:

• transactions that are not on commercially reasonable terms;
• payment in gold or the use of debt swaps;
• payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
• any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People's Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled by or in a joint venture with such persons;
• transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People's Republic of China;
• the unblocking of any property blocked pursuant to the Venezuela Sanctions Regulations; or
• any transaction involving a blocked vessel.

For information on how an entity that is not an "established U.S. entities" (including non-U.S. entities) can be involved in transactions authorized by GL 46, see FAQ 1230.

Yes. Consistent with the term "Venezuelan oil" as defined in section 5(a) of Executive Order 14245, "Imposing Tariffs on Countries Importing Venezuelan Oil," the term "Venezuelan-origin oil" means crude oil or petroleum products extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products.

As defined by the U.S. Energy Information Administration (EIA), petroleum products include unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas, and miscellaneous products obtained from the processing of crude oil (including lease condensate), natural gas, and other hydrocarbon compounds. In keeping with the EIA's standard definition, petroleum products do not include natural gas, liquefied natural gas, biofuels, methanol, and other non-petroleum fuels.

Accordingly, crude oil blends such as Merey 16 or bitumen blends, as well as petroleum products or byproducts, including gasoline, asphalt, flexicoke, and petroleum coke, are considered "Venezuelan-origin oil" for the purposes of GL 46.