On February 13, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 49 and GL 50 (since amended as 50A),[1] continuing the expansion of authorized activities in the Venezuelan oil and gas sectors. These two licenses follow five additional licenses recently issued by OFAC[2] collectively providing distinct pathways for engagement with Venezuelan energy operations while maintaining stringent controls and oversight mechanisms by the U.S. government. GL 49 authorizes negotiation of and entry into contingent contracts for certain new investments in oil or gas sector operations in Venezuela, and GL 50A authorizes transactions by BP, Chevron, Eni, Établissements Maurel & Prom SA, Repsol, and Shell related to oil or gas sector operations in Venezuela.Continue Reading OFAC Issues General Licenses 49 and 50A Authorizing Contingent Investments and Additional Operations in Venezuelan Oil and Gas Sector
Yulia A. Solomakhina
OFAC Issues General License 47 Authorizing Sale of U.S.-Origin Diluents to Venezuela
On February 3, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 47 generally authorizing the export, sale, and supply of U.S.-origin diluents to Venezuela. The issuance of GL 47 comes less than a week after OFAC issued GL 46 on January 29, 2026, authorizing certain transactions related to the lifting, refinement, export, and sale of Venezuelan oil.[1] GL 47 addresses a critical operational need in Venezuela’s oil sector, as diluents are essential for the processing and transport of Venezuelan heavy crude, which is viscous and dense.Continue Reading OFAC Issues General License 47 Authorizing Sale of U.S.-Origin Diluents to Venezuela
OFAC Eases Venezuelan Oil Sanctions Following Maduro Apprehension
Update: On February 10, 2026, OFAC issued GL 46A, which amended GL 46 to clarify that payments for local taxes, permits, or fees are excluded from the requirement to be deposited into Foreign Government Deposit Funds.
On January 29, 2026 the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 46 authorizing certain transactions relating to the lifting, refinement, and trade of Venezuelan-origin oil by established U.S. entities. This marks the first public action by OFAC in revising the general Venezuela sanctions regime since the U.S. apprehension of Nicolás Maduro.[1] GL 46 comes on the heels of the Venezuelan National Assembly’s passage of a new hydrocarbons law aimed at facilitating foreign investment in the Venezuelan hydrocarbon sector.[2] While the issuance of GL 46 is a significant move in easing sanctions under the new Venezuelan administration, its precise scope warrants close review as the new license continues to place strict requirements with respect to operations in the Venezuelan oil sector.Continue Reading OFAC Eases Venezuelan Oil Sanctions Following Maduro Apprehension
Navigating Venezuela Sanctions: Legal Considerations and Anticipated Developments
After the apprehension of Nicolás Maduro on January 3, 2026, the White House has actively advocated for Venezuelan market access for U.S. oil companies. Although a regulatory framework under which such investment can occur remains uncertain, any such arrangement will need to account for the sweeping U.S. sanctions that have been imposed against Venezuela over the past decade in response to alleged human rights abuses, corruption, and the erosion of democratic institutions under the Maduro regime. As of writing, these sanctions remain in full-effect, generally blocking the property of the Government of Venezuela (“GoV”) and restricting U.S. persons (and non-U.S. persons to the extent they are engaging in dealings within U.S. jurisdiction) from engaging in transactions or other dealings with the GoV, entities owned or controlled by, or acting on behalf of, the GoV, including the state-owned oil company Petroleos de Venezuela, S.A. (“PdVSA”), and certain individuals in leadership of the GoV. Moreover, the U.S. government maintains discretion to impose blocking sanctions against parties determined to engage in certain activities, including operating in the defense and security, financial, oil, and gold sectors of Venezuela, as well as any other sectors as determined by the U.S. government in the future. This note provides an overview of key Executive Orders (“E.O.”) constituting the Venezuela sanctions framework, including a description of the status of relevant General Licenses (“GL”), and considerations for the future as the White House explores potential arrangements with Venezuela for U.S. oil company market entry.Continue Reading Navigating Venezuela Sanctions: Legal Considerations and Anticipated Developments
OFAC Expands Sanctions against Russian Energy Sector
On January 10, 2025, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued sweeping new sanctions targeting Russia’s energy sector, including the imposition of a new petroleum services ban, expanded secondary sanctions authority, and designations of certain Russian oil producers, insurance providers, and more than 180 so-called “shadow fleet” vessels. Until this time, U.S. sanctions specific to the Russian energy sector generally were limited to a ban on maritime services for oil and petroleum products sold at or below the relevant price caps, designations of specific projects, traders, or vessels, and certain pre-2022 targeted sectoral sanctions and secondary sanctions authorities. Continue Reading OFAC Expands Sanctions against Russian Energy Sector
Sanctions on Russian Securities Infrastructure Create Additional Hurdles to Divesting from Russia
The Russian financial services sector remains a key target of U.S., UK, and EU sanctions. As discussed below, a number of recent such sanctions against Russia and countermeasures by the Russian government have further complicated efforts for investors seeking to divest listed securities from Russia.Continue Reading Sanctions on Russian Securities Infrastructure Create Additional Hurdles to Divesting from Russia
OFAC Sanctions Gazprombank, Continues to Target Russian Financial Sector and Foreign Financial Institutions
On November 21, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) designated additional entities operating in the Russian financial services sector, including Gazprombank Joint Stock Company (“Gazprombank”), the largest and, until November 21, most significant remaining non-sanctioned Russian bank that has served as the primary conduit for processing payments for Russian gas sold to third countries since March 2022. Specifically, OFAC designated Gazprombank pursuant to Executive Order 14024 (“E.O. 14024”) for operating or having operated in the financial services sector of the Russian Federation economy, and noted that Gazprombank had served as a “conduit for Russia to purchase military materiel,” and also was used by the Russian government to pay military personnel and their families.Continue Reading OFAC Sanctions Gazprombank, Continues to Target Russian Financial Sector and Foreign Financial Institutions
Russian Countermeasures: The Governmental Commission Tightens Conditions for Exits by Investors From Unfriendly Jurisdictions
As anticipated by recent media coverage, the Governmental Commission for Control over Foreign Investments (the “Governmental Commission”) published its October 15, 2024 decision tightening conditions for exits by investors from “unfriendly” jurisdictions (i.e., those that have imposed sanctions against Russia) (the “Decision”). Prior to the Decision, the Governmental Commission had already imposed various conditions when approving sales of equity in Russian companies by parties from “unfriendly” jurisdictions. Such conditions were typically communicated to the applicants in the excerpts from the minutes of the Governmental Commission meetings. The Decision lists the revised conditions that should generally be imposed by the Governmental Commission when approving such sale transactions:Continue Reading Russian Countermeasures: The Governmental Commission Tightens Conditions for Exits by Investors From Unfriendly Jurisdictions
U.S., UK, and EU Sanctions Alignment: U.S. IT and Software Sector Service Bans and Export Controls Take Effect as Russia Sanctions Continue to Expand
On September 12, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) June 12, 2024 determination entitled “Prohibition on Certain Information Technology and Software Services” entered into effect. The determination prohibits the direct or indirect provision to Russia from the United States or by U.S. persons of (1) information technology (“IT”) consultancy and design services and (2) IT support services and cloud-based services for enterprise management software and design and manufacturing software (collectively, the “IT Services Prohibition”). On September 16, 2024, similarly focused export controls took effect, prohibiting the export, reexport, or transfer (in-country) to Russia and Belarus of certain EAR99 software relating to enterprise resource planning (ERP) and other commercial functions, which were issued earlier by the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) on June 12, 2024.Continue Reading U.S., UK, and EU Sanctions Alignment: U.S. IT and Software Sector Service Bans and Export Controls Take Effect as Russia Sanctions Continue to Expand
New Russian Decree Imposes Restrictions on Transfer of IP Rights
On May 20, 2024, President Putin signed Decree No. 430 (the “Decree”), effective the same day. The Decree establishes restrictions on the acquisition of IP rights by Russian persons from so-called “unfriendly” jurisdictions. The term “unfriendly” jurisdiction has been used in other countersanctions regulations and includes all foreign states that commit unfriendly acts towards the Russian Federation and Russian legal entities and natural persons (i.e., countries that have introduced sanctions against Russia, including the European Union, United Kingdom, and United States).Continue Reading New Russian Decree Imposes Restrictions on Transfer of IP Rights