Careers

Diversity, Equity & Inclusion

Experience

Innovation

Interactive Maps

Locations

About

Pages

Meet our team of innovators
Ask us how we do it

Professionals

Insights

Services

Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

Home | Thompson Hine LLP

Atlanta

Chicago

Cincinnati

Cleveland

Columbus

Dayton

Los Angeles

Minneapolis

New York

Silicon Valley

Washington, D.C.

On January 29, 2026, the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) issued&nbsp;<a href="https://ofac.treasury.gov/media/934886/download?inline" target="_blank" rel="noreferrer noopener">Venezuela-related General License 46</a>, &ldquo;Authorizing Certain Activities Involving Venezuelan-Origin Oil.&rdquo;&nbsp;The general license authorizes all transactions prohibited by the Venezuela Sanctions Regulations, 31 C.F.R part 591, including those involving the Government of Venezuela, Petr&oacute;leos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50% or greater interest, &ldquo;that are 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.&rdquo;
The scope of this general license authorization is limited to an established U.S. entity, defined as &ldquo;any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.&rdquo;&nbsp;OFAC notes that the transactions authorized &ldquo;include arranging shipping and logistics services, including chartering vessels, obtaining marine insurance and protection and indemnity (P&amp;I) coverage, and arranging port and terminal services, including with port authorities or terminal operators that are part of the Government of Venezuela.&rdquo;&nbsp;The general license also authorizes &ldquo;commercially reasonable payments in the form of swaps of crude oil, diluents, or refined petroleum products.&rdquo;
Further, the general licenses is applicable provided that: (1) Any contract for such transactions &ldquo;specify that the laws of the United States or any jurisdiction within the United States govern the contract and that any dispute resolution under the contract occur in the United States;&rdquo; and (2) &ldquo;Any monetary payment to a blocked person is made into the Foreign Government Deposit Funds, as specified in <a href="https://www.govinfo.gov/content/pkg/FR-2026-01-15/pdf/2026-00831.pdf" target="_blank" rel="noreferrer noopener">Executive Order 14373</a> of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury.&rdquo;&nbsp;
Any person that exports, reexports, sells, resells, or supplies Venezuelan-origin oil to countries other than the United States pursuant to this general license must provide a detailed report to the Departments of State and Energy ten days after the execution of the first of such transactions, and every 90 days thereafter while such transactions are ongoing.
While this general license is intended to encourage U.S. oil companies to return to Venezuela and reinvest in that country&rsquo;s oil infrastructure and production, there remain specific transactions and payment terms that are not authorized.&nbsp;Thus, the terms of the general license and continuing restrictions on certain transactions must be carefully reviewed.

OFAC Issues General License Authorizing Certain Oil Activities in Venezuela

Services