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Venezuelan crude is moving again. Exports averaged 1.11 million barrels a day over January to August against 944,000 a day last year, on Kpler’s count, and the market has read that as a recovery. It is a recovery in volume and a redirection in distance, and the second of those matters more to anyone who owns tonnage. The dominant destination moved from 13,656 nautical miles away to 2,124, on the American navigation table. Venezuela’s largest buyer last year has bought nothing since Maduro was captured by US forces on January 3, on Bloomberg data cited by EnergyNow, and Kpler has China at 5,000 barrels a day across the eight months. The licence that reopened this trade to American companies was issued 26 days after that, on January 29, so it did not cause the exit and this brief does not claim it did. What it did was build the door with two paragraphs that shut China’s route through it. OFAC has since amended that licence four times. It gave away the requirement for United States governing law, widened arbitration to London, Paris and Singapore, extended the licence to petrochemicals and conceded that Venezuelan sovereign law applies. Across all four amendments, paragraph (b) did not change by a single character.
📋 In This Issue:
⚖️ The Story:
The licence that opened Venezuelan crude to an established US entity and the two paragraphs inside it this desk has found no shipping coverage working through, what precisely those exclusions reach and what they do not, the twenty-six days that rule the licence out as a cause, the four amendments that gave away United States governing law and left paragraph (b) untouched to the character, the two versions the Federal Register still has not carried, where the two data counts disagree and why this desk will not difference them, the 13,656 miles that became 2,124, the ports that cannot load what the country is selling, and what the barrel is worth now the discount buyer has gone.
📊 By The Numbers:
The 5,000 a day, the 1.11 million a day, the 13,656 miles against 2,124, the 30-day wait, the two docks of seven and the paragraph that survived four amendments intact.
🔍 Why It Matters:
What changes for the VLCC owner, the charterer, the crude trader and the marine underwriter.
👀 What To Watch:
The five markers, including the finding that would prove this reading wrong and the one that would only put its scale wrong.
🚨 Gosships Signal:
What it means when everything in a licence is negotiable except two paragraphs.
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January 3, 2026: United States forces capture Nicolás Maduro in Caracas and fly him out of the country. Al Jazeera publishes a video screengrab, taken from a social media post and routed through AFP, captioned "Venezuelan President Nicolas Maduro is escorted by DEA agents inside the headquarters of the US Drug Enforcement Administration in New York, on January 3, 2026", and reports that the Colombian government condemned “Washington’s early Saturday morning attacks on Venezuela which included strikes on military targets and Maduro’s capture”. NPR later describes it as “the January military mission that captured then-President Nicolas Maduro on federal narcoterrorism and drug trafficking charges.” Venezuela’s Supreme Tribunal of Justice directs the vice president, Delcy Rodríguez, to take over the office the same day, and she takes the oath as acting president on January 5. Officials in Rodríguez's government said in January and February that they still considered Maduro Venezuela's legitimate head of state, and Al Jazeera reports on September 3 that the government has since gone silent on the question.
January 29, 2026: OFAC issues Venezuela General License 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil”. It authorises an established US entity to lift, export, sell, store, market, deliver and transport Venezuelan-origin oil, including refining it, subject to conditions. Paragraph (b) sets out what the authorisation does not reach. Paragraph (b)(1) excludes “Payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro”. Paragraph (b)(3) excludes “Any transaction involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China”. The licence also requires that authorised contracts be governed by United States law and that disputes be resolved in the United States.
January 2026: Chinese buyers stop taking Venezuelan cargoes. EnergyNow, citing data compiled by Bloomberg, reports on September 4 that China “hasn’t bought any barrels since the US ouster of Maduro in January”. The removal is dated to January 3 and General License 46 issued on January 29, so the stop was already in train 26 days before the licence existed. The same report describes what the trade had been: “Deep discounts versus comparable crude grades from elsewhere made Merey popular with China’s independent refiners”, and “The shipments are less about China securing energy supply and more about recouping its oil-backed loans.”
February 10, 2026: OFAC issues General License 46A. Paragraph (a)(2) gains a carve-out “excluding payments for local taxes, permits, or fees”. Paragraph (b) is unchanged. OFAC announces it the same day on its recent actions page, alongside General License 48 and General License 30B.
March 13, 2026: OFAC issues General License 46B, retitled to cover “Venezuelan-Origin Oil or Petrochemical Products”, adding a 45-line annex of harmonised system codes for fertilizer products and precursors. Paragraph (b) is unchanged. OFAC announces it the same day, alongside General Licenses 48A and 49A and amended FAQs 1226 and 1227.
May 7, 2026: The Federal Register catches up, publishing the first three of the series together at 91 FR 24719 under document number 2026-09092.
June 10, 2026: OFAC issues General License 46C, announced the same day alongside amended licences 47A, 48B, 50B, 51B, 52A and 54A. Paragraph (a)(1) is rewritten so that dispute resolution proceedings “occur in the United States, the United Kingdom, France, or Singapore”, and a new note concedes that “certain aspects of the underlying activity in Venezuela may be subject to applicable Venezuelan law and regulations, including laws and regulations governing the exercise of Venezuela’s sovereign regulatory authority”. Paragraph (b) is unchanged. The Federal Register has not carried General License 46C.
August 3, 2026: OFAC issues Venezuela General License 5Y, “Authorizing Certain Transactions Related to the Petroleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After September 17, 2026”. The collateral behind that bond is an interest in CITGO Holding. The authorisation bites on September 17.
August 21, 2026: Reuters reports that Venezuelan loading infrastructure cannot keep pace with what the country is selling, with "tankers having to wait up to 30 days to load because of aging infrastructure" against vessels historically "getting in and out of Venezuelan waters in less than a week". The report states that the Jose port "handles about 70% of the country's overall exports", that "In mid-August, only two of Guaraguao's seven docks were fully in service", and that PDVSA "is increasingly being charged thousands of dollars for demurrage" which "it has agreed to pay only in crude". It has "PDVSA and its partners" as the parties "unable to surpass 1.25 million barrels per day of exports", against terminals that handled more than 2.5 million a day when output peaked above 3 million a day more than two decades ago. It records traders including Vitol and Trafigura moving "over 140 million barrels of crude and fuel this year".
August 27, 2026: OFAC reissues eight Venezuela general licences, among them General License 46D, now titled “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products”. Baker McKenzie’s sanctions note records the substantive change: contracts authorised under these licences “no longer need to include a clause requiring the contract to be construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States”, with dispute resolution now permitted, in Baker McKenzie’s words, where proceedings “occur in the United States, the United Kingdom, France, or Singapore”. The exclusions at (b)(1) and (b)(3) carry over in the same terms. The licence also requires reports “ten days after the execution of the first of such transactions and every 90 days thereafter while such transactions are ongoing.”
September 1, 2026: Reuters reports August exports. “Venezuela’s oil exports remained almost unchanged in August at 1.17 million barrels per day”. Exports to the United States “averaged some 553,000 bpd, below the record of 786,000 bpd in July”. Shipments to India “rose 66% from the previous month to 297,000 bpd” and exports to Europe “almost tripled to some 260,000 bpd”. Trading houses “including Vitol and Trafigura managed to keep their export volumes stable at some 597,000 bpd”, while Chevron’s liftings “declined slightly to 286,000 bpd from 293,000 bpd”. Fuel imports ran at “some 166,000 bpd”, more than double July’s 81,000. The report attributes August loading delays in part to “A power blackout in late July that hit all of PDVSA’s crude upgraders and blending stations”. Reporting by Marianna Parraga and Mircely Guanipa.
September 2, 2026: Chevron announces from Houston, on the day its Venezuelan contracts are signed in Caracas, that it "will invest more than $7bn through its Venezuela joint ventures to double oil production to about 600,000 barrels per day over the next five years”, with “total production costs are expected to be less than $20 per barrel”. Chief executive Mike Wirth says “Our ability to grow at low cost is quite different than if we were going into a greenfield area that didn’t have roads, that didn’t have water, that didn’t have power.” Al Jazeera puts current national output at about 1.25 million barrels a day against more than 3 million two decades ago, and records that Donald Trump pushed a $100 billion reconstruction plan for the country's energy sector after Nicolás Maduro was removed from office in January. The same day, Reuters reports Goldman Sachs as saying it "does not see output returning to pre-2018 levels of more than 2 million barrels per day over the next few years.”
September 4, 2026: Kpler data published by The National covers January to August 2026. “Total Venezuelan exports averaged 1.11 million bpd, up from 944,000 bpd last year”. “Exports to the US surged by 238 per cent to average 515,000 bpd in the first eight months of 2026”. “Shipments to India grew tenfold to about 224,000 bpd”, while “flows to China fell by a hundredfold to just 5,000 during the same period”. “US-bound volumes peaked at about 834,000 bpd in July before easing to 437,000 bpd in August”.
⚖️ The Story
What The Licence Actually Says
On January 29 the Office of Foreign Assets Control issued General License 46. It is a short document, and this desk has found no shipping coverage that works through it.
Paragraph (a) is the part the general coverage picked up. It authorises “an established U.S. entity” to do the things that make a crude trade possible: the “lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, including the refining of such oil”. That is the door, and it is worth being exact about who it is for. The trade was never closed. Venezuela exported 944,000 barrels a day last year on Kpler’s count. What paragraph (a) did was open it to an established US entity, which is a narrower class than US persons at large. Note 1 to the licence defines that class by a date, and the date is doing work. An established US entity is one organised in the United States on or before January 29, 2025, a full year before this licence issued. A company incorporated to take advantage of the opening does not qualify. That cut-off sits in all five versions.
Paragraph (b) is the part this desk has not seen covered, and it is where the story is. Paragraph (b) lists what the authorisation does not reach.
Two of those exclusions matter more than the rest.
