On April 14, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela” (GL 56), and Venezuela General License 57, “Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals” (GL 57). OFAC also issued one Venezuela-related Frequently Asked Question (FAQ), FAQ 1248. 

These actions represent the latest steps in a continuing U.S. policy of progressively opening channels for commercial and financial engagement with Venezuela, extending the series of general licenses that OFAC has issued since early 2026 across the energy, petrochemical, minerals, and infrastructure sectors.

General License 56

GL 56 broadens the authorization for U.S. persons to conduct commercial-related negotiations of contingent contracts directly with the Government of Venezuela, covering sectors and transaction types that extend beyond those addressed in earlier licenses. Like predecessor licenses such as GL 49A and GL 55, GL 56 permits the negotiation and entry into contingent contracts, but requires that the performance of any such contract remain expressly contingent upon separate authorization from OFAC. GL 56 also incorporates limitations that mirror those in other recently issued GLs (e.g., requirement for commercially reasonable terms, no dealings with foreign adversaries or other sanctioned persons).

General License 57

GL 57 addresses the financial services dimension of Venezuela-related transactions, authorizing “financial services” transactions involving (1) certain Venezuelan banks, and (2) individuals who are blocked only because they deemed to be part of the “Government of Venezuela” as defined in Executive Order 13884.

The Venezuelan banks with which transactions are authorized by GL 57 are: (1) Banco Central de Venezuela; (2) Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela); (3) Banco Digital de los Trabajadores Banco Universal C.A.; and (4) Banco del Tesoro, C.A. Banco Universal (Banco del Tesoro). The authorization also applies to entities owned 50% or more by one or more of these banks.

OFAC provides a broad definition of “financial services,” including nearly all standard banking-related activities, in particular: “maintaining, operating, or closing of accounts; loans; transfers; transfers of funds; banking services; money transfer services; collection; presentment; promise; order; consignment; the acceptance of deposits; insurance; guarantees; cash withdrawals; check services; Automated Clearing House (ACH) transfers; wire transfers; debit card, prepaid card, Automated Teller Machine transactions, and any other payments as defined under the Uniform Commercial Code Article 3-602; the issuance and use of payment cards and digital wallets; currency exchange; U.S. dollar-denominated banking, payment, and correspondent account services; services in connection with the collection, forwarding, processing, or receipt of funds or remittances; services in connection with the processing or receipt of salary, pension, annuity, payroll, and other employment-related payments or benefits; transfers of funds sent through mobile money, mobile wallets, digital bank accounts, credit cards, debit cards, online payments, or other digital technology; related safety, fraud-prevention, screening, authentication, cybersecurity, and security services and technologies; investments; securities; and commodity futures or options.”

GL 57 contains a “Note 2” explaining that U.S. financial institutions that process GL 57-authorized transactions may rely on the originator or beneficiary of a funds transfer with regard to compliance with GL 57, provided that the processing financial institution does not know or have reason to know that the transaction is not in compliance with GL 57.  This appears to reduce compliance burden on correspondent and intermediary banks involved in transactions with these entities.

GL 57 also contains a “Note 3” explaining that nothing in GL 57 excuses compliance with obligations under the Bank Secrecy Act (BSA) and related FinCEN regulations, signaling that OFAC is aware of FinTech and other novel forms of payment activities in Venezuela, and seeks to ensure that such market participants are properly assessing whether such activities separately comply with the U.S. Bank Secrecy Act (BSA) and related laws, and perhaps in particular that BSA-regulated institutions continue to determine if any Venezuela-activity warrants the filing of a Suspicious Activity Report (SAR).

FAQ 1248

OFAC issued FAQ 1248 to clarify the reporting requirements in General Licenses 46B-48A, 50A-52, and 54 should be completed by the parties engaged in the primary authorized activity. Parties that are only indirectly involved or providing services ancillary to the primary authorized activity are not required to file reports. For example, a company providing services for the generation of electricity in Venezuela under GL 48A would need to report such activities pursuant to that license, but a bank processing payments related to those services does not also need to provide a report.

Practical Implications

The practical implications of these new actions are significant.

For commercial sector participants, including trading companies, logistics providers, and project developers, GL 56 widens the gateway for preliminary engagement with the Government of Venezuela, permitting structured negotiations and the entry into contingent investment or commercial arrangements without requiring a specific license at the outset.

For GL 57, this authorization is particularly significant for U.S. banks, FinTechs, digital asset companies, and other financial intermediaries that process payments, maintain correspondent accounts, or provide other financial services in connection with Venezuela-related activity authorized under the broader suite of Venezuela general licenses.

Additionally, many entities interested in new opportunities in Venezuela pursuant to the other OFAC-issued general licenses found themselves limited by which financial institutions would process their payments. OFAC’s issuance of GL 57 provides significantly more assurance to U.S. and other financial institutions that there are at least four banks in Venezuela with whom they can legally transact and it establishes a clearer legal basis needed to support the expanding scope of authorized commercial activity in Venezuela.

FAQ 1248 reinforces this distinction as well: parties conducting the primary authorized activity bear the reporting obligations under the applicable general license, while banks and other service providers processing related payments do not. This clarification reduces compliance friction for financial institutions supporting the growing range of permitted Venezuela dealings.

Crowell will continue to monitor for new and updated OFAC guidance on Venezuela.