GL-52C

Summary

General License No. 52C authorizes established U.S. entities to engage in transactions with PdVSA and PdVSA Entities that would otherwise be prohibited by Executive Orders 13884 and 13850. It also authorizes related transactions involving the Government of Venezuela and allows blocked individuals to sign contracts in their official capacity on behalf of PdVSA. Monetary payments to blocked persons must be directed into the Foreign Government Deposit Funds or another account as instructed by the U.S. Department of the Treasury.

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 activities authorized in paragraph (a)
• Signing and execution of contracts or agreements by blocked individuals acting in their official capacity as officers, employees, or authorized representatives of PdVSA or PdVSA Entities
• Export, reexport, sale, resale, or supply of Venezuelan-origin oil or Venezuelan-origin petrochemical products (subject to reporting requirements)

Conditions

Transactions must be conducted by an 'established U.S. entity' (organized under U.S. law on or before January 29, 2025). Contracts must require dispute resolution in the U.S., U.K., France, or Singapore. Monetary payments to blocked persons (excluding local taxes, permits, or fees) must be made into the Foreign Government Deposit Funds. Transactions involving SDN-listed individuals (other than PdVSA/PdVSA Entities), Russian, Iranian, North Korean, Cuban persons, Chinese-controlled entities, blocked vessels, certain debt/bond transactions, non-commercially reasonable payment terms, digital currency, and governance changes to PDV Holding/Citgo are not authorized.

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 identifying the parties involved, a description of the transactions (products, quantities, values, dates, and countries of ultimate destination), and any taxes, fees, or other payments provided to the Government of Venezuela. Reports are due ten days after the execution of the first such transaction and every 90 days thereafter while such transactions are ongoing.