Frequently Asked Questions

514. If a U.S. person entered into a revolving credit facility or long-term loan arrangement for the Government of Venezuela prior to the sanctions effective date, what are the restrictions under E.O. 13808 on drawdowns from that facility? Do all drawdowns and disbursements pursuant to the parent agreement need to carry repayment terms of 90 days or less (for PdVSA) or 30 days or less (for the rest of the Government of Venezuela)?

If a U.S. person entered into a long-term credit facility or loan agreement prior to August 25, 2017, drawdowns and disbursements with repayment terms of 90 days or less (for PdVSA) or 30 days or less (for the rest of the Government of Venezuela) are not prohibited. Drawdowns and disbursements… Read more

649. What does Executive Order 13857 of January 25, 2019 "Taking Additional Steps to Address the National Emergency with Respect to Venezuela" do and how does this impact OFAC's Venezuela-related sanctions?

Executive Order 13857 of January 25, 2019 "Taking Additional Steps to Address the National Emergency with Respect to Venezuela" broadens the definition of the term "Government of Venezuela" to include persons that have acted, or have purported to act, on behalf of the Government of Venezuela,… Read more

661. What does General License 9H authorize with respect to Petróleos de Venezuela, S.A. (PdVSA) debt and equity and what are the implications for U.S. and non-U.S. persons?

General License (GL) 9H authorizes U.S. persons to engage in all transactions prohibited by subsection 1(a)(iii) of Executive Order (E.O.) 13808 or by E.O. 13850 , each as amended by E.O. 13857 , or by E.O. 13884 , as collectively incorporated into the Venezuela Sanctions Regulations, 31 CFR part… Read more

1246. Does General License 52 authorize the sale of certain shares of CITGO that are the subject of Crystallex International Corporation v. Bolivarian Republic of Venezuela?

No. A specific license will be required before any sale is executed in the Crystallex case. Notwithstanding the existence of any general licenses under the Venezuela Sanctions Regulations (VSR), a specific license from OFAC is required for the entry into a settlement agreement, or for the… Read more

1245. What activities are authorized by Venezuela General License (GL) 52, "Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A."?

GL 52 authorizes, subject to its conditions and exclusions, transactions prohibited by Executive Orders (E.O.s) 13884 or 13850 with Petróleos de Venezuela, S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, "PdVSA Entities"), by… Read more

662. What does General License 3I authorize with respect to Government of Venezuela debt, and what are the implications for U.S. and non-U.S. persons?

General License 3I (GL 3I) authorizes U.S. persons to engage in all transactions related to, the provision of financing for, and other dealings in the bonds specified in the Annex to GL 3I (GL 3I Bonds) that would be prohibited by subsection 1(a)(iii) of Executive Order (E.O.) 13808 or by E.O.… Read more

1247. Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46B, 51A, and 52?

No, provided that non-U.S. persons comply with certain conditions outlined in GLs 46B , 51A , and 52 , as described below. Subject to certain conditions, GLs 46B, 51A, and 52 authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), as… Read more

956. For the Belarus, Russian Harmful Foreign Activities (Russia) Ukraine-/Russia-related, and Venezuela-related sanctions programs, how does OFAC view modifications to pre-existing loans, contracts, or other agreements to replace London Interbank Offered Rate (LIBOR) as the reference rate?

In July 2017, the United Kingdom Financial Conduct Authority (FCA) announced the "future cessation and loss of representativeness" of the ICE Benchmark Administration's 35 global reference rates, the LIBOR rates. In light of the discontinuation of LIBOR as a benchmark reference rate, OFAC is… Read more

1248. Since January 2026, OFAC has issued a series of Venezuela-related General Licenses related to purchases and investment in Venezuela's natural resource sectors, such as Venezuela-related General Licenses (GLs) 48A and 50A, that include a reporting requirement. Which parties are responsible for providing such reports pursuant to those General Licenses?

In general, the parties engaged in the primary authorized activity are responsible for complying with the applicable reporting requirements in these Venezuela-related GLs. Parties that are only indirectly involved or providing services ancillary to the primary authorized activity are not required… Read more

1250. Are Iranian digital asset exchanges blocked under OFAC sanctions?

Yes. Executive Order (E.O.) 13599 , as implemented by section 560.211(b) of the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), blocks the property and interests in property of Iranian financial institutions. An Iranian financial institution is blocked pursuant to E.O. 13599… Read more

Frequently Asked Questions

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