OFAC Eases Sanctions On Financial Services And Commercial-Related Transactions In Venezuela

On April 14, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two general licenses under the Venezuela Sanctions Regulations (“VSR”): General License No. 56 (“GL 56”) and General License No. 57 (“GL 57”). GL 56 authorizes companies to negotiate commercial deals with the Government of Venezuela, provided that the entry into and performance of such contracts are contingent on OFAC approval. GL 57 permits a broad range of financial services involving certain Venezuelan banks and government-affiliated individuals.

Together, while these licenses do not amount to a lifting of sanctions, they represent a meaningful relaxation of U.S. sanctions for commercial and financial services transactions in Venezuela and create important new pathways for businesses and financial institutions to position themselves in the Venezuelan market.

This client alert provides an overview of each license and key considerations for companies and financial institutions assessing opportunities in Venezuela.

General License 56

GL 56 authorizes U.S. persons and companies to negotiate commercial contracts with the Government of Venezuela, provided that the entry into and performance of any such contract is made expressly contingent upon separate authorization from OFAC. Therefore, U.S. companies can negotiate deal terms, but they may not enter into or perform the contract until OFAC provides approval.

Under GL 56:

• “Government of Venezuela” is defined very broadly. It covers not just the state itself, but also any political subdivision, agency, instrumentality, state-owned or state-controlled entity, and anyone acting on behalf of the Venezuelan government. The Central Bank of Venezuela falls within the definition of “Government of Venezuela.”
• “Contingent contracts” is also broadly defined, covering executory contracts, pro forma invoices, agreements in principle, bids and proposals (including responses to public tenders), binding MOUs, and similar arrangements. Most forms of preliminary or conditional commercial agreements are covered, which gives companies flexibility in how they structure early-stage negotiations.

Importantly, GL 56 contains significant restrictions and does not authorize:

• Any transactions that are separately prohibited under other Venezuela-related executive orders — notably Executive Order (“E.O.”) 13808 (which restricts dealings in Venezuelan government bonds and Petróleos de Venezuela, S.A. (“PdVSA”) debt) and E.O. 13835 (which restricts equity interests in PdVSA or entities 50% or more owned by the Venezuelan government). This means GL 56 does not open the door to bond purchases, debt trading, or equity investments in Venezuelan state-owned enterprises;
• Transactions involving persons (i) located in or organized under the laws or Russia, Iran, North Korea, or Cuba; or (ii) entities owned or controlled by or in a joint venture with persons from these excluded jurisdictions;
• Transactions with Venezuelan or U.S. entities that are owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of China;
• Payment terms that are not “commercially reasonable,” i.e., involving debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
• The entry into settlement agreements or enforcement of liens, judgments, or other orders that affect blocked property;
• Transactions involving persons on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”) or entities that are 50% or more owned by SDN-listed persons; or
• The unblocking of any property blocked under 31 CFR Chapter V. Therefore, existing asset freezes remain in place.

For businesses, GL 56 creates an opportunity to begin negotiating commercial arrangements with the Venezuelan government. However, GL 56 authorizes only the negotiation of contingent contracts; it does not authorize the execution or performance of those contracts absent a separate OFAC authorization. This two-step structure means that companies should structure their negotiations and any associated expenditures accordingly, including by ensuring that preliminary agreements clearly state that performance is contingent on OFAC approval and that no binding obligations arise prior to such approval.

The restrictions on transactions involving persons from Russia, Iran, North Korea, Cuba, and China also warrant careful counterparty diligence, as the Venezuelan government maintains significant commercial and diplomatic ties with several of these jurisdictions. In practice, these carve-outs may substantially limit the pool of permissible counterparties in sectors where Venezuelan state-owned enterprises have existing joint ventures or supply arrangements with entities from excluded jurisdictions. Companies should conduct thorough ownership and control analyses of potential Venezuelan counterparties to confirm that no excluded jurisdiction nexus exists before commencing negotiations.

Notably, the continuing prohibitions under E.O. 13808 and E.O. 13835 mean that GL 56 does not create opportunities in the Venezuelan sovereign debt market or for equity investments in PdVSA or other Venezuelan state-owned enterprises. Businesses considering commercial engagement in the energy sector should be particularly attentive to these limitations, given PdVSA’s central role in the Venezuelan economy.

General License 57

GL 57 authorizes a wide range of financial services to, from, or for the benefit of the following persons:

1. Banco Central de Venezuela;
2. Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela);
3. Banco Digital de los Trabajadores Banco Universal C.A.;
4. Banco del Tesoro, C.A. Banco Universal (Banco del Tesoro);
5. Any entity in which one or more of the above banks own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; and
6. Any individual whose property is blocked solely under E.O. 13884 because they fall within the definition of “Government of Venezuela” (including current government employees) — but not anyone who is individually named on the SDN List.

GL 57 also covers any transactions involving the Government of Venezuela that would otherwise be prohibited by E.O. 13884, provided that those transactions are necessary for carrying out the financial services described above. In practice, this means that ancillary steps needed to facilitate an authorized financial service — such as correspondent banking transactions or clearing activities — are also permitted.

The definition of “financial services” under GL 57 is notably broad. It includes account maintenance, loans, banking and money transfer services, insurance, ACH and wire transfers, payment card and digital wallet transactions, currency exchange, U.S. dollar-denominated correspondent account services, payroll and employment-related payments, digital payment transfers, cybersecurity services, investments, securities, and commodity futures or options.¹GL 57 defines “financial services” as including “maintaining, operating, or closing of accounts; loans; transfers; transfers of funds; banking services; money transfer services; collection; presentment; promise; order; consignment; the acceptance of deposits; insurance; guarantees; cash withdrawals; check services; Automated Clearing House (ACH) transfers; wire transfers; debit card, prepaid card, Automated Teller Machine transactions, and any other payments as defined under the Uniform Commercial Code Article 3-602; the issuance and use of payment cards and digital wallets; currency exchange; U.S. dollar-denominated banking, payment, and correspondent account services; services in connection with the collection, forwarding, processing, or receipt of funds or remittances; services in connection with the processing or receipt of salary, pension, annuity, payroll, and other employment-related payments or benefits; transfers of funds sent through mobile money, mobile wallets, digital bank accounts, credit cards, debit cards, online payments, or other digital technology; related safety, fraud-prevention, screening, authentication, cybersecurity, and security services and technologies; investments; securities; and commodity futures or options.” As a practical matter, this definition covers nearly every type of banking and financial product that a U.S. institution might offer, making GL 57 a significant opening for financial institutions that seek to serve Venezuelan clients or process Venezuela-related transactions.

For financial institutions, GL 57 opens the door to providing a wide range of financial services involving key Venezuelan banks and government-affiliated individuals. The breadth of the “financial services” definition means that most standard banking products and payment processing services are now within scope, including correspondent banking, payment card services, insurance, currency exchange, and digital payment transfers. This represents a substantial commercial opportunity for institutions with the risk appetite and compliance infrastructure to serve the Venezuelan market.

Nonetheless, financial institutions should proceed carefully under this general license. GL 57 does not unblock previously frozen assets, and SDN List exclusions require rigorous screening of all counterparties and beneficial owners. The list of authorized Venezuelan banks is limited to four named institutions and their majority-owned subsidiaries; institutions must verify that the specific entity they are transacting with falls within the license’s scope. For individual counterparties, GL 57 covers only those whose property is blocked solely under E.O. 13884 by virtue of falling within the definition of “Government of Venezuela”; individuals who are separately named on the SDN List remain fully blocked. Financial institutions should implement enhanced screening protocols that distinguish between these categories.

GL 57 contains a safe harbor provision for financial institutions, which are allowed to rely on originator or beneficiary representations when processing funds transfers, provided that the processing institution does not know or have reason to know that the transaction falls outside the scope of GL 57. Although this provision provides a degree of comfort, it is limited by the “know or have reason to know” standard. Therefore, institutions that process high volumes of Venezuela-related transactions should consider implementing additional monitoring controls to identify red flags that could impute constructive knowledge. In addition, all standard anti-money laundering and counter-terrorism financing obligations under the Bank Secrecy Act, the USA PATRIOT Act, and FinCEN regulations remain fully applicable, and institutions should expect heightened regulatory scrutiny of Venezuela-related transactions even where those transactions fall within the scope of GL 57.

Key Considerations

These general licenses represent a meaningful shift in U.S. sanctions policy toward Venezuela’s commercial and financial services sector. For businesses, GL 56 creates an opportunity to begin negotiating commercial arrangements with the Venezuelan government now, positioning themselves to move quickly if OFAC grants performance authorization. For financial institutions, GL 57 opens the door to providing a wide range of financial services involving key Venezuelan banks and government-affiliated individuals. However, both general licenses include significant limitations and compliance obligations for businesses. Companies should review the authorizations carefully and conduct due diligence, including SDN screening of all parties, before entering into any transactions. Given the complexity of Venezuela’s sanctions landscape, companies and financial institutions that are considering entering into the Venezuelan market should consider updating internal compliance policies and training materials to reflect the new authorizations and their limits. Companies should also bear in mind that general licenses can be amended, narrowed, or revoked at any time, and should structure their engagements to account for the possibility that the regulatory environment may shift.

We continue to monitor Venezuela-related sanctions developments and have extensive experience helping companies navigate their compliance obligations as they explore new commercial opportunities in the country. Please contact any member of our team to discuss how these developments may affect your business.