commercials with PDVSA
General License No. 52C states that any export of Venezuelan oil or petrochemical products to countries other than the United States will require reporting to the State Department and the Department of Energy.
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury issued this September 14th General License No. 52C, which replaces LG 52B and expands the flexibility for Petróleos de Venezuela S.A. (Pdvsa).
This amendment enables U.S. entities established to carry out the prohibited transactions in Executive Orders 13884 and 13850, and sets parameters under which these U.S. entities may conduct operational and commercial transactions with Petróleos de Venezuela, S.A. (PDVSA) and its subsidiaries with at least 50% ownership participation.
Authorizations
General License No. 52C applies exclusively to U.S. entities that have been incorporated on or before January 29, 2025, authorizing them to enter into and carry out commercial or contractual relationships within the framework provided.
It also establishes that all payments directed to blocked persons or entities must be deposited in the Foreign Governments Deposit Funds —as stipulated in Executive Order 14373— or in the specific accounts designated by the U.S. Department of the Treasury.
Only payments corresponding to local taxes, permits, or fees are excluded from this requirement.
Likewise, any contract entered into under this license must formally stipulate that arbitration and dispute resolution procedures are carried out in the jurisdictions of the United States, the United Kingdom, France, or Singapore.
They emphasize that any export of Venezuelan oil or petrochemical products to countries other than the United States will require the submission of detailed reports to the Department of State and the Department of Energy.
Prohibitions and Exclusions
Despite the general authorization to conduct operations, the Treasury Department maintained restrictions to define the scope of the commercial exchange. With this, the Trump Administration maintains a regulated channel for energy operations and strengthens mechanisms for financial oversight and international compliance.
In that regard, the license explicitly prohibits any transaction involving persons, companies, or joint ventures associated with Russia, Iran, North Korea, Cuba, or China. It also restricts changes that alter the board of directors, management, or corporate governance of CITGO Petroleum Corporation, Citgo Holding, or PDV Holding.
Likewise, payments in cryptocurrencies or tokens issued by Venezuela are prohibited, as are debt swaps, transactions in gold, or unreasonable commercial terms.
The measure does not authorize the settlement of sovereign bonds or Pdvsa, nor the execution of seizures, arbitral awards, or court judgments against blocked assets.
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