WILLEMSTAD — The Government of Curaçao is watching closely as a new U.S. sanctions licence may open legal pathways for Venezuelan oil to be stored, shipped and potentially processed on the island, amid ongoing developments in international energy policy and sanctions enforcement. The recent issuance of General License No. 46 (“GL 46”) by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) marks one of the most significant shifts in U.S. sanctions policy on Venezuelan oil in years and could have implications for Curaçao’s dormant refinery infrastructure, including facilities at Bullenbaai and Emmastad.
What the New U.S. Licence Means
On January 29, 2026, OFAC issued GL 46, authorising certain activities involving Venezuelan-origin crude oil — including exportation, storage, marketing, purchase, delivery and transport — provided they are carried out by “established U.S. entities” and meet specific legal and compliance conditions. This licence effectively allows transactions historically prohibited under Venezuela sanctions to proceed under carefully defined circumstances.
Under GL 46, authorised activities can extend to shipping logistics, port and terminal services, and other oil sector operations that are “ordinarily incident and necessary” to lifting, storing or transporting Venezuelan crude. Any contracts with the Government of Venezuela or its state oil company PDVSA must be governed by U.S. law and include U.S. dispute resolution clauses. Financial payments to sanctioned parties must be sent to designated Foreign Government Deposit Funds, as outlined by U.S. regulations designed to safeguard Venezuelan oil revenues under American control.
Despite this expanded authorisation, the licence excludes certain transactions — such as those involving entities linked to Russia, Iran, North Korea or Cuba, and some payment formats such as debt swaps or digital currencies — and does not authorise upstream activities like oil exploration or production. The focus remains on downstream or transit activities that connect Venezuelan oil to global markets in ways that align with U.S. policy objectives.
Potential Impact on Curaçao
For Curaçao, GL 46 could create new legal avenues for commercial entities to use the island’s oil infrastructure — long dormant since the closure of the refinery — for storage and transshipment of Venezuelan crude. Local stakeholders have suggested the policy could underpin renewed activity at Bullenbaai and Emmastad, if companies comply with the strict OFAC conditions. The government reportedly sees possibilities for operational and commercial reactivation, particularly if local firms and foreign partners meet legal and regulatory requirements.
Prime Minister Gilmar Pisas has expressed optimism about these developments, noting that government efforts will focus on accommodating applications for use or operation of Curaçao’s petroleum facilities, in cooperation with partners such as 2BAYS and CRU, provided all legal conditions are met. This suggests the island is positioning itself to attract sanctioned-sanction compliant oil transactions that could boost local logistics and storage activity.
Broader Context
The GL 46 licence emerges against the backdrop of evolving U.S. sanctions policy on Venezuela, including additional authorisations for diluent exports and related oil sector activity. It reflects an effort by the current U.S. administration to open segments of Venezuela’s energy sector to U.S. actors, while still maintaining leverage through compliance obligations and reporting requirements.
However, experts note that while the licence may make certain commercial activities possible, actual implementation requires careful legal and compliance planning, including adherence to conditions governing payment channels, contract law and reporting obligations to U.S. authorities. Companies and jurisdictions interested in participating must understand these requirements thoroughly to avoid sanctions violations.
Looking Ahead
Although the new OFAC licence does not automatically usher in a fully fledged Venezuelan oil trade for Curaçao, it arguably removes some legal barriers that previously deterred sanctioned-era transactions. Curaçao’s authorities and private sector actors are likely to continue evaluating how best to position the island’s infrastructure for potential use, while ensuring compliance with international sanctions law and local regulation.
The coming months will show whether GL 46 leads to concrete activity involving Venezuelan oil supplies on Curaçao, and how the island’s government and businesses will navigate the complex legal landscape created by U.S. sanctions policy shifts.