The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a series of energy-related general licenses authorizing U.S. persons to purchase, sell, transport and otherwise deal in crude oil and petroleum products originating from Venezuela, Russia and Iran, while also expanding authorized trade and investment in Venezuela’s minerals sector. Critically, for Venezuela, OFAC’s authorization is open-ended for established U.S. entities. For Russia and Iran, OFAC issued a series of narrower, time-limited authorizations permitting the sale and delivery of crude oil cargoes already loaded on vessels as of specified cutoff dates with Iran General License U (now expired) notably briefly authorizing the direct importation of Iranian crude into the United States for the first time in decades. In this memo, we provide an overview of each of these actions and the parallel delisting of Venezuela’s acting president, reflecting a coordinated policy effort by the U.S. government to manage global energy supply disruptions and deepen engagement with the Venezuelan government.
Of the more significant OFAC energy-related licenses expanding these energy markets, OFAC issued Venezuela-related General License 52 (“GL 52”),[1] which generally provides open-ended authorization for U.S. entities organized on or before January 29, 2025 (“established U.S. entities”) to engage in a wide range of oil, gas and petrochemical transactions with state-owned oil company Petróleos de Venezuela, S.A. (“PdVSA”) and its subsidiaries. Because PdVSA effectively serves as the gatekeeper to Venezuela’s oil sector—controlling the vast majority of the country’s crude oil production and export infrastructure—the authorization to transact directly with PdVSA and its subsidiaries is critical to participation in the Venezuelan energy market and represents the most significant easing of Venezuela-related sanctions in years. For Russia, Russia-related General License temporarily authorizes, through May 16, 2026, the sale and delivery of Russian-origin crude oil and petroleum products already loaded on vessels—including blocked vessels—as of April 17, 2026[2] following OFAC’s October 2025 designation of Rosneft and Lukoil on OFAC’s SDN List. Iran General License U (“GL U”) temporarily authorizes, through April 19, 2026, the sale and delivery of Iranian-origin crude oil and petroleum products loaded on vessels as of March 20, 2026, including, notably, their importation into the United States.[3]
This alert provides an overview of each of these licensing actions—their scope, conditions and limitations—and the broader context that led to their near-simultaneous issuance, including the Administration’s effort to stabilize energy markets and avoid significant supply disruptions while preserving, and in some cases actively expanding, the underlying U.S. sanctions architecture.
Venezuela: General License 52 and Related Developments
GL 52 provides a broad authorization for “established U.S. entities”[4] to engage in transactions otherwise prohibited under E.O. 13884 and E.O. 13850 with PdVSA and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”). Authorized activities include the lifting, exportation, re-exportation, sale, resale, supply, storage, marketing, purchase, delivery or transportation of Venezuelan-origin oil and petroleum products; the provision to Venezuela of diluent goods, services and technologies necessary for exploration, development or production activities in the oil, gas or petrochemical products sectors; entry into new investment contracts for exploration, development or production activities in Venezuela’s oil, gas or petroleum product sectors; the formation of new joint ventures or other entities in Venezuela related to such activities; and all transactions ordinarily incident and necessary to the authorized transactions.
GL 52 also authorizes transactions with the Government of Venezuela that are necessary for the activities set forth above, subject to the same payment conditions.
GL 52’s authorizations are subject to two principal conditions:
- Governing Law / Dispute Resolution. Any contract for transactions with PdVSA or PdVSA Entities must specify that the laws of the United States (or any U.S. jurisdiction) govern the contract and that any dispute resolution under the contract occur within the United States.[5]
- Payment Routing. Any monetary payment to a blocked person—other than payments for local taxes, permits or fees—must be made into the Foreign Government Deposit Funds, as established by E.O. 14373, or into any other account as instructed by the U.S. Department of the Treasury.[6] This payment mechanism is central to the Administration’s strategy of preserving Venezuelan oil revenues for future disposition consistent with U.S. foreign policy objectives. Notably, E.O. 14373 expressly prohibits any attachment, judgment, lien, execution, garnishment or other judicial process against the Foreign Government Deposit Funds, declares such a threat an “unusual and extraordinary threat” to national security and foreign policy warranting a national emergency, and directs the Secretary of the Treasury to hold the funds in a custodial capacity as sovereign property of the Government of Venezuela.[7] Although described here in the context of GL 52, the requirement to route payments to blocked persons through the Foreign Government Deposit Funds is a common structural condition shared across the broader suite of Venezuela-related general licenses discussed in this alert, including GL 51A, GL54 and GL55.
GL 52 imposes a dual-agency reporting obligation on persons that export, re-export, sell or supply Venezuelan-origin oil or petrochemical products to countries other than the United States pursuant to license.[8] Such persons must provide a detailed written report to both the Department of State and the Department of Energy identifying the parties, transaction details (including products, quantities, values, dates and countries of ultimate destination) and any payments to the Government of Venezuela.[9] The initial report is due within 10 days of the first covered transaction, with subsequent reports due every 90 days.[10] This reporting obligation does not, on its face, appear to apply to transactions in which Venezuelan-origin oil is imported directly into the United States.[11] GL 52 is focused on current energy transactions and does not more broadly address corporate matters involving Venezuela energy companies, including certain debt transactions, transactions in gold or Venezuelan crypto (e.g., petro or petro gold), dealings with SDNs other than those listed in the GL, or transactions involving persons in or organized under the laws of Russia, Iran, North Korea or the People’s Republic of China (“PRC”).
GL 52 is the most significant in a series of new and amended general licenses issued since late January 2026[12]—none of which carry an expiration date—expanding authorizations for trade and investment primarily in Venezuela’s oil, gas, gold and petrochemical sectors. Key preceding licenses include GL 46B (authorizing lifting, sale and transportation of Venezuelan-origin oil and petrochemical products for U.S. importation),[13] GL 47 (authorizing exportation of U.S.-origin diluents to Venezuela),[14] GL 48A, first issued as GL 48 on Feb. 10, 2026[15] (authorizing provisions of goods, technology and services for Venezuelan energy sector operations),[16] GL 50A, first issued on Feb. 13, 2026 as GL 50[17] (providing entity-specific authorization for six major energy companies, including Chevron, BP, Eni, Repsol, Shell and Maurel & Prom)[18] and GL 51 (extending the licensing framework to Venezuelan-origin gold).[19]
On March 27, 2026, OFAC continued expanding this licensing framework by issuing GL 51A—which replaced and superseded GL 51 in its entirety—along with two new general licenses, GL 54 and GL 55, further broadening authorized activities in Venezuela’s mineral sector.[20] These outward licenses share common structural features with GL 52, including “established U.S. entity” eligibility requirements, Foreign Government Deposit Funds payment-channeling conditions and counterparty exclusions covering Russia, Iran, North Korea, Cuba and PRC. Venezuela-related sanctions have been imposed through a series of executive orders[21] and are implemented through the Venezuela Sanctions Regulations (“VSR”).[22]
GL 51A authorizes established U.S. entities to engage in transactions ordinarily incident and necessary to the exportation, re-exportation, sale, resale, supply, storage, purchase, delivery or transportation of Venezuelan-origin minerals, including gold, involving the Government of Venezuela, CVG Compania General de Mineria de Venezuela CA (“Minerven”) or any entity in which Minerven owns, directly or indirectly, a 50 percent or greater interest (collectively, “Minerven Entities”). Authorized activities include arranging shipping and logistics services, chartering vessels, obtaining marine insurance and P&I coverage arranging port and terminal services, and conducting commercial, legal, technical, safety and environmental due diligence. GL 51A also authorizes the processing or refining of Venezuelan-origin minerals, but explicitly prohibits any such processing or refining in Russia, Iran, North Korea, Cuba or PRC. Notably, GL 51A removed language from GL 51 that had specifically referenced the transportation of Venezuelan-origin gold for importation into the United States and the refining and exportation of such gold—a change that, according to an OFAC spokesperson, reflects a broadening of the license’s scope to cover all minerals, not just gold. Reporting obligations require detailed reports to the Departments of State and the Interior—including supply chain due diligence documentation—due within 10 days of the first transaction and every 30 days thereafter. GL 51A does not authorize transactions involving persons in Russia, Iran, North Korea or Cuba, or Venezuelan or U.S. entities owned or controlled by PRC persons.[23]
GL 54 authorizes transactions ordinarily incident and necessary to the provision from the United States, or by a U.S. person, of goods, technology, software or services for the exploration, development, mining, extraction, processing, refining or production of minerals, including gold, in Venezuela—including transactions with the Government of Venezuela, Minerven or Minerven Entities. Authorized activities include processing of payments, arranging shipping and logistics, obtaining marine insurance and P&I coverage, arranging port and terminal services and the maintenance of minerals operations, including the refurbishment or repair of items used for minerals activities. GL 54 does not authorize payment terms that are not commercially reasonable, involve debt swaps or payments in gold or are denominated in Venezuelan government digital currency (including the petro); transactions involving persons in Russia, Iran, North Korea, Cuba or the PRC; or the formation of new joint ventures or other entities in Venezuela. GL 54 imposes reporting obligations requiring detailed transaction reports to the Departments of State and the Interior, due within 10 days of the first transaction and every 90 days thereafter.[24]
GL 55 authorizes transactions related to the negotiation of and entry into contingent contracts for new investment in Venezuela’s minerals sector, including the gold sector, provided that the performance of any such contract is made expressly contingent upon separate OFAC authorization. For purposes of GL 55, “contingent contracts” include executory contracts, executory pro forma invoices, agreements in principle, bids or proposals in response to public tenders, binding memoranda of understanding and similar agreements. GL 55 also authorizes the expansion of existing operations in Venezuela and the formation of new joint ventures or other entities related to minerals-sector activities, as well as prefatory steps such as conducting commercial, legal, technical, safety, and environmental due diligence and assessments. GL 55 does not authorize transactions involving persons in Russia, Iran, North Korea, Cuba or the PRC.[25]
On April 1, 2026, OFAC also removed acting Venezuelan President Delcy Rodríguez from the SDN List. Rodríguez has led Venezuela’s government since the capture of President Nicolás Maduro in January 2026.[26] This delisting is a significant step in normalizing U.S.-Venezuela relations, as it enables Rodríguez to engage directly with U.S. companies and investors without the constraints of blocking sanctions and signals the Administration’s recognition of her as a cooperative partner in the broader effort to open Venezuela’s energy and minerals sectors to American investment.
Finally, on April 14, 2026, OFAC issued two additional Venezuela-related general licenses: GL 56, authorizing commercial-related negotiations of contingent contracts with the Government of Venezuela,[27] and GL 57, authorizing financial services transactions involving certain Venezuelan banks and Government of Venezuela individuals.[28] Together, these additional licenses represent a meaningful expansion of OFAC’s Venezuela framework, extending the contingent contract negotiation authorization beyond the minerals-sector to encompass all commercial dealings with the Venezuelan government, and providing the underlying financial services infrastructure—including banking, payment processing and correspondent account services involving key Venezuelan state banks such as Banco Central de Venezuela and Banco de Venezuela—necessary to operationalize that broader commercial engagement.
Russia: GL 134B and the Parallel Energy-Related Authorization
The issuance of GL 134A[29] capped a sequence of Russia-related sanctions developments that have unfolded over the past five months, moving from a prolonged period of relative inaction to an escalation. For the first 10 months of the current administration, OFAC did not impose significant new Russia-related sanctions designations, consistent with the Administration’s broader effort to obtain a negotiated settlement of the conflict between Russia and Ukraine.[30] That period ended on October 22, 2025, when OFAC designated two major Russian energy companies—Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”)—along with a number of their Russian-based subsidiaries, adding them to the SDN List.[31] OFAC simultaneously issued several accompanying general licenses, including GL 124A (a durable, open-ended authorization for transactions related to the Caspian Pipeline Consortium and Tengizchevroil LLP, preserving the flow of Kazakh-origin oil),[32] GL 126 (a temporary wind-down license for Rosneft and Lukoil transactions, which expired November 21, 2025)[33] and GL 127 (authorizing divestiture and settlement of Rosneft/Lukoil debt and equity, also expired November 21, 2025).[34] OFAC subsequently issued additional entity-specific licenses, including GL 129A (a durable authorization for Rosneft’s German downstream subsidiaries)[35] and GL 131D (authorizing through May 1, 2026, the negotiation of contingent contracts for the sale of Lukoil International GmbH and related maintenance activities).[36] Beginning in March 2026, OFAC issued a series of new general licenses facilitating the orderly disposition of Russian petroleum cargoes already in transit, framed explicitly as a response to global energy and supply restrictions.
GL 133, issued on March 5, 2026, and which expired on April 4, 2026, provided an initial, narrowly tailored authorization limited to the sale and delivery of Russian‑origin crude oil loaded on vessels on or before a specified cutoff date, to purchasers organized under Indian law—suggesting an effort to accommodate a key strategic partner, as India has been a major purchaser of Russian crude since 2022.[37]
GL 134, issued on March 12, 2026, and which was superseded by GL 134A a week later, broadened the geographic scope beyond India. Secretary Bessent stated that GL 134 was intended to “promote stability in global energy markets” and “keep prices low as we address the threat and instability posed by the terrorist Iranian regime”—framing the Russia energy GLs explicitly as a response to supply disruptions caused by ongoing events in Iran and the related disruptions in the Strait of Hormuz.[38] GL 134A,[39] issued on March 19, 2026, and which expired on April 11, 2026, replaced GL 134 in its entirety and authorized, through April 11, 2026, all transactions ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products of Russian Federation-origin loaded on any vessel on or before March 12, 2026—including vessels blocked under applicable Russian- and Ukraine-related sanctions. Less than a week after GL 134A’s expiration, on April 17, 2026, OFAC issued GL 134B, replacing and superseding GL 134A in its entirety. GL 134B extends the authorization through May 16, 2026, and updates the vessel loading cutoff date to April 17, 2026. GL 134B retains the same scope of authorized activities as GL 134A, including safe docking and anchoring, crew health and safety, emergency repairs, environmental mitigation and vessel services, such as management, crewing, bunkering, piloting, registration, flagging, insurance, classification and salvage. GL 134B further retains the same exclusion framework as GL 134A, which is more granular than the predecessor GL 134’s exclusions, where: it does not authorize any transaction involving a person located in or organized under the laws of Iran, North Korea, Cuba, the Covered Regions of Ukraine (as defined by E.O. 14065) or the Crimea Region of Ukraine (as defined by E.O. 13685), or any entity owned or controlled by or joint venture with such persons. The addition of explicit North Korean, Cuban and Ukrainian territorial exclusions mirrors the counterparty-exclusion architecture of the recent Venezuelan GLs—a further indication that OFAC is applying a consistent policy template across its energy-related licensing actions.
The time-limited nature of these authorizations—GL 133 expired April 4, 2026, GL 134A expired April 11, 2026 and GL 134B is set to expire May 16, 2026—underscores their character as targeted wind-down measures rather than a broader relaxation of Russia sanctions, though the successive extensions and expanded loading cutoff dates suggest OFAC’s willingness to adapt to evolving market conditions. The structural parallels between GL 134B’s exclusion framework and GL 52’s exclusion framework, moreover, underscore a broader policy objective: ensuring that energy-related sanctions relief does not benefit Iran, North Korea, Cuba or other sanctioned jurisdictions.
On April 14, 2026, OFAC issued amended Russia-related General License 128C, authorizing certain transactions involving Lukoil retail service stations located outside of Russia,[40] and Russia-related General License 130A, authorizing transactions involving certain Lukoil entities in Bulgaria.[41]
The issuance of GL 134B on April 17, 2026, just two days after Secretary Bessent stated that “[w]e will not be renewing the general license on Russian oil,” demonstrates that OFAC retains flexibility to issue new time-limited authorizations to facilitate orderly disposition of Russian petroleum cargoes amid ongoing pressure on global energy markets.[42] With the ongoing Iran war and the pressure on energy markets continuing, it remains to be seen whether OFAC will issue further extensions or additional authorizations for the Russia energy market beyond GL 134B’s May 16, 2026 expiration.
Iran: GL U and the Broader Policy Context
On March 20, 2026, in keeping with the Administration’s adaptability on sanctions implementation to prevent disruptions in global energy supply, OFAC issued Iran GL U. In announcing the GL U, Secretary Bessent stated that “the Department of the Treasury is issuing a narrowly tailored, short-term authorization permitting the sale of Iranian oil currently at sea” and that “[b]y temporarily unlocking this existing supply for the world, the United States will quickly bring approximately 140 million barrels of oil to global market, expanding the amount of worldwide energy and helping to relieve the temporary pressures on supply caused by Iran.”[43]
GL U authorizes, through April 19, 2026, all transactions ordinarily incident and necessary to the sale, delivery or offloading of Iranian crude oil or petroleum loaded on any vessel—including blocked vessels—on or before March 20, 2026. GL U is issued under an unusually broad set of Iran- and Russia-related sanctions regulations, including the Iranian Transactions and Sanctions Regulations (31 C.F.R. pt. 560), several Iran-related Executive Orders, the Russian Harmful Foreign Activities Sanctions Regulations and the Ukraine-/Russia-Related Sanctions Regulations, signaling the breadth of the legal prohibitions that GL U is temporarily lifting. Authorized activities include safe docking and anchoring, crew health and safety, emergency repairs, environmental mitigation and vessel services such as management, crewing, bunkering, piloting, registration, flagging, insurance, classification and salvage.
Of particular note, GL U expressly authorizes the importation of Iranian-origin crude oil and petroleum products into the United States, where such importation is ordinarily incident and necessary to the sale, delivery or offloading authorized by the license. Given the direct importation of Iranian crude oil into the United States has been categorically prohibited for decades, this explicit authorization is a notable feature of GL U. As noted above, GL U’s counterparty exclusions are significantly narrower than those of GL 52 and GL 134B, omitting any restrictions on transactions with persons connected to Russia, PRC or Iran. Of particular significance, GL U does not replicate the Iran exclusion present in GL 134B—a distinction that may reflect the Administration’s intent to maximize the pool of potential purchasers of Iranian crude during the brief authorization window.
Conclusion
The issuance of general licenses across three major oil-producing jurisdictions subject to significant U.S. sanctions, together with the parallel expansion of minerals-sector authorizations, the broadening of commercial and financial services engagement with the Government of Venezuela and the delisting of Venezuela’s acting president, reflects a coordinated policy effort by the U.S. Government to manage global energy supply disruptions and deepen engagement with the Venezuelan government. Taken together, these authorizations signal an approach that prioritizes market continuity, U.S. energy interests, and petroleum and other extractive energy price stability, while preserving—and, in the Venezuela context, actively expanding—the underlying sanctions architecture through new payment routing and reporting mechanisms rather than outright relief.
U.S. and non-U.S. companies with exposure to any of these programs should monitor further OFAC action closely in the coming weeks given the short duration of many of these general licenses. In recent years, OFAC has historically targeted third-country entities and persons—particularly in the PRC—that have been viewed as facilitating or benefiting from the Iranian oil trade. Given the short duration of these licenses, they may be more appropriately viewed as a global oil price stability measure than a fundamental change in the oil sanctions policy.
Notwithstanding these expanded authorizations, companies with operations or counterparty exposure in Venezuela, Russia or Iran should remain attentive and should continue to monitor the evolving political and security risks in each of these countries. On April 15, 2026, Secretary Bessent announced: “[w]e will not be renewing the general license on Iranian oil. Again, that was oil that was on the water prior to March 11th, right? So all that has been used.”[44] However, two days later, OFAC issued GL 134B, extending authorization for Russian-origin oil through May 16, 2026 with an updated loading cutoff date. The fluid environment, combined with the short-term nature of several general licenses, adds to the uncertainty and underscores the importance of staying updated on regulatory changes and implementing robust compliance strategies. Additionally, businesses should remain mindful of risks associated with money laundering corruption, and sanctions evasion by third parties when operating in these jurisdictions.
We will continue to monitor for further U.S. sanctions developments in this area and will issue further updates as appropriate.
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[1] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 52, Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A. (Mar. 18, 2026), available here.
[2] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 134B, Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of April 17, 2026 (Apr. 17, 2026), available here. GL 134B, issued on April 17, 2026, replaced and superseded a GL 134A, which temporarily authorized the delivery and sale of crude oil and petroleum products of Russian origin loaded on vessels as of March 12, 2026, through April 11, 2026. See General License No. 134A, Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026 (Mar. 19, 2026), available here.
[3] Off. of Foreign Assets Control, Dep’t of the Treasury, Iranian Transactions and Sanctions Regulations General License U: Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026 (Mar. 20, 2026), available here.
[4] “Established U.S. entity” is defined as any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.
[5] GL 52 ¶ (a)(1).
[6] GL 52 ¶¶ (a)(2), (b); See also E.O. 14373, § 2, 91 Fed. Reg. at 2046 (defining “Foreign Government Deposit Funds” as funds paid to or held by the U.S. Government in designated Treasury accounts on behalf of the Government of Venezuela or its agencies or instrumentalities, including PdVSA, derived from the sale of natural resources from, or the sale of diluents to, the Government of Venezuela).
[7] E.O. 14373, §§ 1, 3(a), 4(a)–(b), 91 Fed. Reg. at 2045–46.
[8] GL 52 ¶ (d).
[9] GL 52 ¶¶ (d)(1)–(3).
[10] GL 52 ¶ (e).
[11] GL 52 expressly preserves the obligation of all persons to comply with the requirements of other federal agencies, including the Department of Commerce’s Bureau of Industry and Security (“BIS”). GL 52, Note to GL 52.
[12] See generally Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, Venezuela Sanctions, available here (collecting Venezuela-related general licenses).
[13] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 46B, Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products (Mar. 13, 2026), available here; originally issued January 29, 2026 as GL 46, available here; updated as GL 46A on February 10, 2026, available here.
[14] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 47, Authorizing the Sale of U.S.-Origin Diluents to Venezuela (Feb. 3, 2026), available here.
[15] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 48, Authorizing the Supply of Certain Items and Services to Venezuela (Feb. 10, 2026), available here.
[16] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 48A, Authorizing the Supply of Certain Items and Services to Venezuela (Mar. 13, 2026), available here; originally issued February 10, 2026 as GL48, available here.
[17] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 50, Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities (Feb. 13, 2026), available here; originally issued February 10, 2026 as GL48, available here.
[18] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 50A, Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities (Feb. 18, 2026), available here; originally issued February 13, 2026 as GL 50, available here.
[19] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 51, Authorizing Certain Activities Involving Venezuelan-Origin Gold (Mar. 6, 2026), available here.
[20] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, Issuance of New and Amended Venezuela-Related General Licenses (Mar. 27, 2026), available here.
[21] Principally, E.O. 13808 (2017), E.O. 13835 (2018), E.O. 13850 (2018), and E.O. 13884 (2019)—building on the national emergency originally declared in E.O. 13692 (2015).
[22] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, Venezuela Sanctions Regulations, 31 C.F.R. pt. 591 (2026), available here.
[23] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 51A, Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold (Mar. 27, 2026), available here.
[24] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 54, Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela (Mar. 27, 2026), available here.
[25] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 55, Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Minerals Sector (Mar. 27, 2026), available here.
[26] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, Venezuela-related Designation Removal (Apr. 1, 2026), available here.
[27] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 56, Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela (Apr. 14, 2026), available here.
[28] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 57, Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals (Apr. 14, 2026), available here.
[29] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 134A, Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026 (Mar. 19, 2026), available here.
[30] Paul, Weiss, In First Major Escalation of Russian Sanctions During the Second Trump Administration, Treasury Announces New Sanctions on Major Russian Oil Companies and Urges Immediate Ceasefire (Oct. 24, 2025) (discussing the Rosneft and Lukoil designations and accompanying general licenses), available here.
[31] OFAC, Treasury Sanctions Major Russian Oil Companies, Calls on Moscow to Immediately Agree to Ceasefire (Oct. 22, 2025), available here.
[32] Id.
[33] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 126, Authorizing the Wind Down of Transactions Involving Rosneft or Lukoil (Oct. 22, 2025), available here.
[34] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 127, Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Rosneft or Lukoil (Oct. 22, 2025), available here.
[35] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 129A, Authorizing Transactions Involving Rosneft Deutschland GmbH and RN Refining & Marketing GmbH (Mar. 5, 2026), available here; originally issued October 29, 2025 as GL 129, available here.
[36] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 131D, Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities (Mar. 30, 2026), available here; replaced and superseded GL 131C, issued Feb. 26, 2026, available here.
[37] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 133, Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 5, 2026 to India (Mar. 5, 2026), available here.
[38] Treasury Secretary Scott Bessent (@SecScottBessent), X (Mar. 12, 2026), available here.
[39] GL 134, supra note 4.
[40] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 128C, Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia (Apr. 14, 2026), available here.
[41] Off. of Foreign Assets Control, U.S. Dep’t of the Treasury, General License No. 130A, Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria (Apr. 14, 2026), available here.
[42] Press Briefing by Press Secretary Karoline Leavitt, Treasury Secretary Scott Bessent, and Small Business Administrator Kelly Loeffler, White House Daily Briefing, C-SPAN (Apr. 15, 2026), available here.
[43] U.S. Treasury Secretary Scott Bessent (@SecScottBessent), X (Mar. 20, 2026), available here.
[44] Press Briefing by Press Secretary Karoline Leavitt, Treasury Secretary Scott Bessent, and Small Business Administrator Kelly Loeffler, White House Daily Briefing, C-SPAN (Apr. 15, 2026), available here.
