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Specific license applications to perform any contingent contracts executed pursuant to GL 49 will be assessed on a case-by-case basis consistent with U.S. foreign policy and national security priorities. Recent Venezuela-related general licenses issued by OFAC have included various limitations in line with these U.S. priorities, which we encourage parties to consider during contract negotiations. Such restrictions have included prohibitions on transactions involving persons located in the Russian Federation, the Islamic Republic of Iran, the Democratic People's Republic of Korea, the Republic of Cuba, the People's Republic of China, or any entity owned or controlled by or in a joint venture with such persons; required that transactions are conducted on commercially reasonable terms; required that contracts specify certain jurisdictions (the United States, the United Kingdom, France, or Singapore) for dispute resolution; and required that payment of royalties or other funds owed to blocked persons—excluding local taxes, permits, and fees—are made into the Foreign Government Deposit Funds or other accounts designated by Treasury.
Date Updated: August 27, 2026
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No. The dispute resolution requirement in certain Venezuela General Licenses (GL), (e.g., 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A) only requires that contracts governing transactions with the Government of Venezuela (GOV) or certain other blocked persons (e.g., Petróleos de Venezuela, S.A. (PdVSA) in GL 52B or CVG Compañía General de Minería de Venezuela CA in GL 51C) specify that the dispute resolution proceedings relating to the contract occur in the United States, the United Kingdom, France, or Singapore. This requirement does not apply to indirect parties or indirect counterparties involved in transactions authorized by these GLs, 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).
Date Updated: August 27, 2026
Updated on