Quick Summary: On April 14, 2026, OFAC issued GL 56 and GL 57. GL 56 permits transactions necessary to negotiate contingent commercial contracts with the Government of Venezuela across all sectors, provided contracts expressly condition performance on separate OFAC authorization. GL 57 authorizes a wide range of U.S. financial services (accounts, payments, correspondent banking, cards, and digital payment services) with four named Venezuelan state banks and their subsidiaries; AML/FinCEN obligations remain in force.
On April 14, 2026, the Office of Foreign Assets Control (OFAC) issued two new General Licenses under the Venezuela Sanctions Regulations (31 CFR Part 591) that represent a significant further expansion of the U.S. regulatory framework for commercial engagement in Venezuela. General License 56 broadens the authorization for negotiating contingent commercial contracts with the Government of Venezuela across all sectors. General License 57 opens Venezuela’s state banking system to U.S. financial services for the first time, authorizing account services, payment processing, wire transfers, correspondent banking, and a broad range of financial transactions with four named Venezuelan state banks and their subsidiaries.
Together, these licenses address two of the most structurally significant gaps in the prior framework: the limited scope of authorized pre-engagement negotiations, and the difficulty of routing commercial payments through Venezuela’s financial infrastructure. Both licenses were signed by OFAC Director Bradley T. Smith and are effective as of April 14, 2026.
General License 56 — Commercial Contract Negotiations
What GL 56 Authorizes
GL 56 authorizes all transactions ordinarily incident and necessary to engaging in commercial-related negotiations of contingent contracts with the Government of Venezuela, provided that entry into and performance of any such contract is expressly contingent upon separate OFAC authorization. Covered instruments include executory contracts, pro forma invoices, agreements in principle, bids and proposals in response to public tenders, and binding memoranda of understanding.
Key expansion over GL 49A: GL 49A is limited to oil, gas, petrochemical, and electricity sector investments. GL 56 covers commercial negotiations with the Government of Venezuela across all sectors, potentially extending to infrastructure, telecommunications, agriculture, manufacturing, and technology. This is a materially broader authorization.
Government of Venezuela defined broadly: GL 56 tracks E.O. 13884 section 6(d), covering all political subdivisions, agencies, instrumentalities, persons owned or controlled by the GoV, and any person who has acted or purported to act for or on behalf of the GoV.
What GL 56 Does Not Authorize
- Transactions under E.O. 13808 (Venezuelan sovereign bonds and PdVSA debt, including settlement)
- Transactions under E.O. 13835 (GoV equity transfers in PdVSA or other majority-owned entities)
- Settlement agreements or enforcement of judgments, arbitral awards, or other orders involving blocked property
- Non-commercially reasonable terms, debt swaps, gold payments, or Venezuelan digital currency (petro)
- Transactions involving Russia, Iran, North Korea, Cuba, or entities owned/controlled by or in JV with such persons
- Venezuelan or U.S. entities owned/controlled by or in JV with PRC persons
- SDN-listed persons or entities 50%+ owned by SDN-listed persons
Critical Drafting Requirement:
The OFAC performance contingency must appear expressly in every contract, MOU, or agreement executed under GL 56. An implied contingency is legally insufficient. Any binding instrument that does not explicitly condition performance upon separate OFAC authorization is not protected by this license and may constitute an unauthorized transaction under the VSR.
General License 57 — Financial Services for Venezuelan State Banks
What GL 57 Authorizes
GL 57 authorizes all transactions ordinarily incident and necessary to the provision of financial services to, from, or for the benefit of the following institutions and their subsidiaries (50%+ owned entities included):
- Banco Central de Venezuela
- Banco de Venezuela, S.A. Banco Universal
- Banco Digital de los Trabajadores Banco Universal C.A.
- Banco del Tesoro, C.A. Banco Universal
The license also covers GoV individuals blocked solely under E.O. 13884 by virtue of their GoV employment status, excluding SDN-listed individuals. All GoV transactions necessary for the authorized financial services are also authorized under paragraph (b).
Scope of “Financial Services”
The definition is comprehensive and covers the full banking and payments spectrum:
- Account maintenance, operation, and closure; loans; funds transfers
- Wire transfers, ACH transfers, and U.S. dollar correspondent banking services
- Debit cards, prepaid cards, credit cards, and ATM transactions
- Mobile money, digital wallets, and online payment services
- Currency exchange and remittances
- Salary, pension, annuity, and payroll payment processing
- Fraud prevention, cybersecurity, and authentication services
- Securities, investments, and commodity futures or options
This is not a narrow carve-out. GL 57 opens the full spectrum of banking and payment infrastructure for dealings with the four named institutions and their subsidiaries, including in connection with the Foreign Government Deposit Funds payment mechanism required under the existing operational licenses.
Reliance Safe Harbor for U.S. Financial Institutions
U.S. financial institutions processing GL 57 transactions may rely on representations of the originator or beneficiary regarding compliance, provided the processing institution has no reason to know the transaction is non-compliant. This standard correspondent banking protection makes the license operationally viable.
AML/BSA/FinCEN Obligations Remain Fully Operative
GL 57 does not suspend Bank Secrecy Act, USA PATRIOT Act, or FinCEN requirements. AML, KYC, and CTF compliance obligations remain fully operative. Financial institutions may not use GL 57 as a basis for relaxing due diligence or monitoring practices.
Practical Implications
- For companies in all sectors: GL 56 creates a negotiation pathway with Venezuelan government entities across all commercial sectors not previously covered. Infrastructure, telecoms, agriculture, manufacturing, and technology companies now have a pre-engagement authorization, subject to the express contingency requirement.
- For companies with active Venezuela transactions: GL 57 directly resolves the payment execution gap. U.S. banks can now process payments through Banco Central de Venezuela, Banco de Venezuela, and Banco del Tesoro, including in connection with the FGDF mechanism required under existing operational licenses. Review payment mechanics in light of GL 57.
- For U.S. financial institutions: GL 57 is the first 2026 license specifically directed at the financial services sector. Banks, payment processors, money transfer operators, and fintech companies now have explicit authorization to service the four named Venezuelan state banks, with the reliance safe harbor providing correspondent chain protection.
- For investors tracking Venezuelan debt: GL 56 expressly excludes E.O. 13808 and E.O. 13835 transactions. Venezuelan sovereign bonds, PdVSA debt settlement, and GoV equity transfers in PdVSA remain separately governed. GL 5V (effective May 5, 2026) governs the PdVSA 2020 8.5% Bond specifically.
The pace of OFAC general license issuances in 2026 now reaching GL 57 signals that the framework will continue to evolve. Compliance positions should be reviewed regularly against the current GL stack. Companies engaged in Venezuelan transactions should have counsel monitor OFAC publications as a standing practice.
Leech Tishman’s Latin America legal team has developed a comprehensive OFAC compliance framework focused on Venezuela sanctions. Our team is prepared to assist clients throughout the evolving GL landscape through 2026. Our team has significant experience in:
- Transaction-specific GL analysis and written compliance opinions for Venezuela-related deals
- Contract structuring to satisfy U.S. law, U.S. forum, and FGDF payment conditions
- Beneficial ownership and counterparty screening under the 50 Percent Rule
- BIS/export control coordination for goods, technology, and software transactions
- FGDF payment mechanics and State Department reporting compliance
- Market entry strategy and cross-border structuring for Latin American companies and investors
- Ongoing compliance retainer services for companies with recurring Venezuela operations
- Coordination and work with local counsel to ensure that activities are in full compliance under new laws in Venezuela.
For a confidential consultation regarding your specific Venezuela opportunity or compliance question, please contact Head of Leech Tishman’s Latin America Practice, Esteban Elias, at eelias@leechtishman.com.