U.S. Opens Door to Venezuelan Oil—But Routes Payments Into Treasury-Controlled Accounts

On a Tuesday afternoon in late January, as crude tankers idled off Venezuela’s Caribbean coast waiting for instructions, a two-page document quietly appeared on the U.S. Treasury Department’s website.

Labeled “Venezuela-related General License 46,” the order from the Office of Foreign Assets Control (OFAC) authorizes a wide range of oil transactions that had been largely off limits for U.S. companies since 2019. It also establishes a new rule of the game: any money owed to Venezuela’s sanctioned state institutions will no longer flow to Caracas, but into accounts controlled by the U.S. government.

Issued on Jan. 29, less than four weeks after U.S. forces captured President Nicolás Maduro in a raid in northern Venezuela, the license is emerging as the core legal instrument for how Venezuelan oil will be bought and sold in the foreseeable future—and who will control the proceeds.

What General License 46 allows

General License 46 permits “all transactions … ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, including the refining of such oil, by an established U.S. entity,” OFAC wrote.

In practical terms, that language reopens Venezuela’s oil sector to a broad swath of American refiners, traders, and service companies, from major integrated firms to mid-sized independents. It allows them to lift, ship, and refine Venezuelan crude and products, arrange marine insurance and port services, and even conduct oil-for-oil swaps—so long as they meet a detailed set of conditions.

Those conditions amount to an assertion of far-reaching U.S. control over the financial and legal framework around Venezuela’s most important export.

U.S. law, U.S. courts—and U.S.-controlled revenue accounts

Any contract that a qualifying U.S. company signs with the Government of Venezuela or the state oil company, Petróleos de Venezuela, S.A. (PdVSA), must be governed by U.S. law and provide that disputes will be resolved in the United States. OFAC’s text requires such contracts to “be governed by the laws of the United States or any jurisdiction within the United States” and to specify “that any dispute resolution takes place in the United States.”

In addition, any monetary payment that would otherwise be due to a “blocked person”—a term that includes the Government of Venezuela, PdVSA, and the Central Bank of Venezuela—must be deposited not in Venezuelan-controlled accounts but into what are called Foreign Government Deposit Funds, or other accounts designated by the Treasury Department.

Those funds were created on Jan. 9 by President Donald Trump in Executive Order 14373, signed six days after U.S. troops seized Maduro and his wife, Cilia Flores, and flew them to New York to face long-standing narcotics and terrorism charges in federal court.

The executive order authorizes the Treasury to hold “funds, securities, or other financial assets of the Government of Venezuela” in special accounts on its books. It declares that any attempt by private creditors or litigants to attach or seize those funds “will materially harm the national security and foreign policy of the United States” and states that any attachment, lien, or other judicial process against the funds “is prohibited and shall be deemed null and void.”

The order further stipulates that assets in those accounts “have not been, and shall not be, used for any commercial activity in the United States” and will instead be held for public, governmental, or diplomatic purposes for Venezuela, as determined by the U.S. secretary of state.

Taken together, the license and the executive order mean U.S.-authorized oil deals with Venezuela’s state sector will be structured under U.S. law, supervised by U.S. courts, and routed through U.S.-run escrow-style accounts.

“This framework allows for the sale and transport of Venezuelan oil, with the U.S. government retaining control over all funds payable to the Government of Venezuela,” a briefing circulated by international law firm Morgan Lewis said.

Who can participate—and who is excluded

The Treasury rules restrict who can take part. Only “established U.S. entities”—defined as entities organized under U.S. federal or state law on or before Jan. 29, 2025—are eligible to use the license, blocking new shell companies created after that date.

Even qualifying U.S. firms face limits on ownership and partnerships. OFAC states that General License 46 does not authorize transactions involving persons located in, or organized under the laws of, Russia, Iran, North Korea, or Cuba, or entities owned or controlled by them, or joint ventures with them. It also bars transactions involving Venezuelan or U.S. entities that are owned or controlled by—or in a joint venture with—persons in China.

Those exclusions mark a sharp shift from years when Russian and Chinese companies were among PdVSA’s principal partners and creditors, and when Iranian-linked tanker fleets helped move sanctioned oil.

The license also prohibits payment schemes associated with past sanctions-evasion efforts. It does not permit debt swaps, payments in gold, or payments using digital currencies or tokens issued by, for, or on behalf of the Venezuelan government, including the “petro” cryptocurrency launched under Maduro.

OFAC stresses the license “does not authorize the unblocking of any property” and does not allow the use of any vessel that is itself blocked under U.S. sanctions.

Reporting requirements for non-U.S. destinations

For oil shipped from Venezuela to destinations outside the United States under the license, companies must report details to the U.S. State Department and the Department of Energy, including parties involved, volumes, values, destination countries, and any taxes or fees paid to the Venezuelan government. The first report is due 10 days after the initial transaction, and every 90 days thereafter.

From sanctions squeeze to a new architecture

The changes come after a decade in which U.S.-Venezuela relations moved from uneasy coexistence to deep freeze.

Beginning in 2015, the United States imposed targeted sanctions against Venezuelan officials over alleged human rights violations and democratic backsliding. In January 2019, the Trump administration designated PdVSA under a sanctions order targeting Venezuela’s oil sector, blocking its property under U.S. jurisdiction and largely barring U.S. persons from dealings with the company absent specific licenses.

In August 2019, another order blocked all property of the Government of Venezuela in the United States, making any transaction with the government subject to Treasury approval. Combined with mismanagement and infrastructure decay, the sanctions contributed to a collapse in Venezuelan oil production from around 3 million barrels per day in the early 2000s to about 500,000 barrels per day in 2020, according to data from the U.S. Energy Information Administration.

The Biden administration later experimented with conditional relief. A November 2022 license allowed Chevron to resume limited operations in Venezuela, with crude lifted as repayment for debt and profits structured so that PdVSA did not receive cash. In October 2023, a broader license temporarily authorized most oil and gas transactions involving Venezuela, but it was later converted into a wind-down authorization after U.S. officials said Maduro’s government failed to meet electoral commitments.

Those measures were rolled back after Trump returned to office in January 2025. New licenses effectively reimposed strict limits on Chevron and other firms.

After Operation Absolute Resolve

The U.S. raid on Jan. 3, code-named Operation Absolute Resolve, marked a more direct intervention. U.S. officials have said the operation targeted what they described as a “narco-terrorist” network in Venezuelan leadership. Reports from the region have cited more than 20 Venezuelan soldiers and dozens of Cuban personnel killed, along with civilian casualties.

With Maduro in federal custody in New York and Vice President Delcy Rodríguez assuming presidential powers under Venezuela’s constitution, the White House moved quickly to redesign the sanctions architecture to fit the new reality.

Announcing the Jan. 9 executive order, Trump said the United States would “ensure that Venezuela’s oil wealth is safeguarded for the good of the American and Venezuelan people,” and claimed the framework would prevent “corrupt actors and hostile powers” from accessing those revenues. His administration has projected that U.S. firms could ultimately invest more than $100 billion in Venezuela’s oil sector and has referred publicly to plans for the United States to obtain tens of millions of barrels of Venezuelan crude.

Those projections have not been independently verified. Industry executives have cautioned that Venezuela’s aging fields, legal uncertainties, and political volatility will limit the pace of investment.

Venezuela holds roughly 303 billion barrels of proven oil reserves, according to international estimates—the largest endowment in the world. Most of that crude is extra-heavy and requires specialized upgrading or blending with lighter diluents, complicating rapid output increases.

Sovereignty questions—and what comes next

Some Venezuelan technocrats and opposition figures have argued that drawing in foreign capital under strict oversight is the only realistic way to rebuild the country’s economy after years of hyperinflation, blackouts, and mass emigration. Others, including factions within the ruling Socialist Party, see the new framework as an unacceptable loss of sovereignty—particularly the requirement that state oil contracts be governed by foreign law and that revenues be held abroad.

Regional reactions have also been mixed. Several Latin American governments that opposed the January raid have warned it sets a precedent for unilateral military action tied to resource interests. U.S. officials counter that the raid responded to criminal indictments, and say the new oil measures are designed to stabilize Venezuela and prevent further humanitarian deterioration.

For now, General License 46 has no expiration date, though OFAC has reserved the right to amend or revoke it at any time. That leaves Venezuelan officials, foreign investors, and creditors alike watching a new, largely untested system in which the United States acts simultaneously as sanctions enforcer, gatekeeper to oil revenues, and—more than before—arbiter of the contracts governing one of the world’s largest hydrocarbon troves.

Whether that system steers Venezuela toward economic recovery or deepens disputes over sovereignty and control may depend less on two pages published in Washington than on how they are implemented in Caracas, the courts, and the oil fields stretching across the Orinoco Belt.