The U.S. Treasury’s recent issuance of General Licenses 49 and 50 marks a significant evolution in the Venezuela sanctions landscape—and signals that the door to Venezuelan oil is opening wider than it has in years.
Following the removal of Nicolás Maduro on January 3, 2026, the U.S. has moved swiftly to reshape its approach to Venezuelan energy. GL 49 now authorizes U.S. companies to negotiate and enter into contingent contracts for new oil and gas investments in Venezuela — including exploration, development, and joint ventures — provided that actual performance awaits separate OFAC authorization. Meanwhile, GL 50 goes further, authorizing ongoing oil and gas operations for major players like Chevron, BP, Shell, Eni, and Repsol, subject to key conditions: U.S. law must govern contracts, and payments to blocked persons must flow into designated U.S. Treasury accounts.
What makes this moment particularly compelling is the parallel movement on the Venezuelan side. The recently enacted Law of the Partial Reform of the Organic Hydrocarbons Law introduces production-sharing agreements and enhanced legal protections for foreign investors — a loosening of state control not seen since before the Chávez era.
Of course, significant guardrails remain. Both licenses prohibit transactions involving Russia, China, Iran, Cuba, and North Korea, and bar unconventional payment methods like digital currency or gold.
The takeaway? We’re witnessing a rare alignment of U.S. regulatory signals and Venezuelan legislative reform. For companies with the risk appetite and the operational capability, Venezuela may be transitioning from “untouchable” to “opportunity.” But in a landscape this fluid, rigorous due diligence remains essential.
Sources:
[1] Lebow, Cardinal and Guerrero, “Venezuela Legal Shifts May Create Investment Opportunities,” https://www.law360.com/articles/2437564/venezuela-legal-shifts-may-create-investment-opportunities
[2] OFAC General License No. 49
[3] OFAC General License No. 50
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