Abstract

The simultaneous promulgation of Venezuela's 2026 Hydrocarbons Law Reform and issuance of OFAC General License 46 on January 29, 2026, mark a structural shift from prohibition to highly regulated permission. This article analyzes the legal architecture established by six operative general licenses (GL 30B, 46B, 47, 48A, 49A, and 50A)-subsequently consolidated in part by GL 52 (March 18, 2026)-, which operationalize the sector's reopening under the financial oversight of the Executive Order 14373 Foreign Government Deposit Funds mechanism. It examines critical compliance pathways, ...