GL-52A

Summary

General License 52A authorizes established U.S. entities (organized on or before January 29, 2025) to engage in transactions with PdVSA and PdVSA Entities that would otherwise be prohibited by E.O. 13884 or E.O. 13850. Contracts must be governed by U.S. law and resolved in the U.S., UK, France, or Singapore, and most monetary payments to blocked persons must go into Foreign Government Deposit Funds. The license also authorizes related Government of Venezuela transactions necessary to support the PdVSA activities, subject to the same payment conditions. It replaces and supersedes General License No. 52 dated March 18, 2026.

Authorized activities

• All transactions prohibited by E.O. 13884 or E.O. 13850 involving PdVSA or PdVSA Entities by an established U.S. entity
• Transactions involving the Government of Venezuela that are necessary for the authorized PdVSA-related activities
• Export, reexport, sale, resale, or supply of Venezuelan-origin oil or petrochemical products to countries other than the United States (subject to reporting requirements)

Conditions

Transactions must be conducted by an established U.S. entity (organized on or before January 29, 2025). Contracts must be governed by U.S. state or jurisdictional law and require dispute resolution in the U.S., UK, France, or Singapore. Monetary payments to blocked persons (excluding local taxes, permits, or fees) must be made into Foreign Government Deposit Funds or another Treasury-designated account. Excluded are: transactions prohibited by E.O. 13808 (bonds/debt) or E.O. 13835 (equity pledging); settlement agreements or enforcement of liens/judgments against blocked property; transactions involving SDN-listed persons (other than PdVSA/PdVSA Entities); non-commercially reasonable payment terms, gold payments, debt swaps, or Venezuelan government-issued digital currency; transactions involving persons from Russia, Iran, North Korea, or Cuba; transactions involving Venezuelan or U.S. entities owned/controlled by or in joint venture with Chinese persons; unblocking of blocked property; and transactions involving blocked vessels.

Reporting requirement

Any person that exports, reexports, sells, resells, or supplies Venezuelan-origin oil or Venezuelan-origin petrochemical products to countries other than the United States must submit a detailed report to Sanctions_inbox@state.gov and VZReporting@doe.gov. The report must identify: (1) the parties involved, (2) a description of the transactions including products, quantities, values, dates, and countries of ultimate destination, and (3) any taxes, fees, or other payments provided to the Government of Venezuela. The first report is due ten days after execution of the first such transaction, and every 90 days thereafter while such transactions are ongoing.