On January 29, 2026, the Office of Foreign Assets Control of the U.S. Department of the Treasury (“OFAC”) issued General License No. 46 (Authorizing Certain Activities Involving Venezuelan-Origin Oil) (“General License 46”), authorizing certain transactions that would otherwise be prohibited under the U.S.-Venezuela sanctions program. This development follows the capture of Nicolás Maduro Moros on January 3, 2026 and aligns with new U.S. government policy to promote stability and prosperity in Venezuela by reopening, and encouraging reinvestment in, the Venezuelan energy sector. The Trump Administration previously announced that, in furtherance of this objective, between 30 and 50 million barrels of Venezuelan oil would be sold at market price, with proceeds deposited in overseas accounts that are controlled by the United States, and President Trump separately stated that he anticipates U.S. oil companies to invest at least $100 billion in the Venezuelan energy sector.
