Yes. Certain Venezuela general licenses (GLs), including 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A, require that any contract for authorized transactions with the Government of Venezuela or certain other blocked persons (e.g., Petróleos de Venezuela, S.A. in GL 52B or CVG Compañía General de Minería de Venezuela CA in GL 51C) specify that dispute resolution proceedings relating to the contract or its breach occur in the United States, the United Kingdom, France, or Singapore. This requirement relates to the jurisdiction in which dispute resolution proceedings must occur, rather than the law governing the underlying contract.

No. Effective August 27, 2026, parties seeking to enter into a contract authorized by certain Venezuela General Licenses (GLs) (e.g., 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A) with the Government of Venezuela (GOV) or certain other blocked persons (e.g., Petróleos de Venezuela, S.A. in GL 52B or CVG Compañía General de Minería de Venezuela CA in GL 51C) are no longer required to include a choice of law provision in the contract. On August 27, 20206, OFAC amended these GLs to remove the requirement that the terms of such contracts be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States.

OFAC amended these GLs in response to investment-related reforms made by the GOV since January 2026. The U.S. government continues to support the efforts by U.S. businesses to reinvest in Venezuela to strengthen America’s national security in the Western Hemisphere and help restore Venezuela as a responsible, prosperous ally of the United States.

These GLs still require dispute resolution proceedings to occur in the United States, United Kingdom, France, or Singapore. Please see FAQ 1268 for additional information.