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ES Prequalification

Compliance · 6 min read

Licenses 48D and 49Bin Venezuela

What each license authorizes, on what conditions, and what a U.S. company should check before signing. Not legal advice.

Published · By GS&E team

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Venezuela is going through its most intense wave of blackouts since 2019, and there is ample scope to restore transmission networks and substations. For a U.S. company, the question before any bid is whether it can do that work and under which authorization.

General License 48D:power-sector services

Issued by OFAC on September 28, 2026, it authorizes services for the generation, transmission, storage or distribution of electricity in Venezuela. It comes with conditions: contract disputes must be resolved in the United States, the United Kingdom, France or Singapore; payments to blocked persons go into the Foreign Government Deposit Funds; and there are reports to the State Department and the Department of Energy.

General License 49B:negotiate, not perform

It allows negotiating new-investment contracts in the power sector, but performing them is expressly contingent on separate OFAC authorization. Negotiating is not performing.

What doesnot change

The Government of Venezuela, including its state power company, remains blocked whether or not it appears on the SDN List, unless exempt or authorized (OFAC, FAQ 680). And a specific license only authorizes its named holder and the transactions it lists: it does not extend to partners or subcontractors.

specific licenses only authorize the licensee(s) to engage in certain transactions that would otherwise be prohibited

OFAC, frequently asked questions

Before signing:what to check

  • Which license exactly covers the work, and who holds it.
  • List screening of every party, including beneficial owners.
  • Dispute and payment clauses compatible with the license.
  • An anti-corruption program and third-party review.
  • A written opinion from a sanctions lawyer.

GS&E has been a Florida LLC since 2009 and does not appear on the SDN List (checked on 2026-10-19). Its compliance page, under legal review, describes how the authorization for each job is documented.

Sources

  • OFAC, General License 48D (28-09-2026)
  • OFAC, General License 49B
  • OFAC, FAQ 680
  • Americas Quarterly (19-08-2026)

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