Case Study: Navigating GL 46A/47 Diluent & Crude Shipments

Synchronizing U.S. Naval Clearance with New OFAC General Licenses in Post-Transition Venezuela.

Date: February 2026

Vessel: Confidential (Aframax Tanker)

Route: Houston, USA → Jose Terminal, Venezuela → U.S. Gulf Coast

Challenge: Managing the first authorized "Diluent-for-Crude" swap under the new 2026 "Southern Spear" maritime blockade.

1. The Challenge: The Dual-Frontier Risk

In early February 2026, a U.S.-based energy major sought to restart heavy crude liftings from the Jose Terminal. The operation faced a "Double-Bind":

  • Technical Need: Heavy Venezuelan crude cannot flow without U.S.-origin diluents. Shipping these diluents was strictly prohibited until the issuance of General License 47 on February 3, 2026.

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  • Blockade Risk: The U.S. Navy’s Operation Southern Spear was actively seizing "uncoordinated" tankers in the Caribbean. Any clerical error in the manifest could lead to a military interdiction.

  • Banking Gridlock: Despite the new licenses, the client’s correspondent bank refused to process port dues, fearing "residual" Maduro-era sanctions.

2. Our Solution: The "White-Channel" Protocol

SanctionedShipping.com acted as the Lead Compliance Liaison, executing a 3-tier clearance strategy:

  • Step 1: Contractual "2026 Riders": We drafted bespoke clauses for the Charter Party ensuring the contract was governed by U.S. Law and disputes resolved in U.S. Courts—a mandatory requirement under GL 46A and GL 47.

  • Step 2: Payment Shielding: We coordinated with the U.S. Treasury to ensure all monetary payments (excluding local port fees) were routed into the newly established Foreign Government Deposit Fund as per Executive Order 14373. This provided the "Safe Harbor" the banks required to release funds.

  • Step 3: Naval Liaison & Pre-Notification: We utilized the MSCHOA/NCAGS style reporting for the Caribbean. By pre-filing the vessel's GL 47 authorization with the Joint Task Force Southern Spear, we secured a "Green Lane" transit, avoiding the boarding and inspection delays affecting other tankers.

3. The Result: Restoring the Energy Flow

The voyage was the first of its kind to be completed under the full 2026 regulatory framework:

  • Successful Swap: Delivered 500,000 barrels of U.S. naphtha (diluent) and successfully lifted 700,000 barrels of heavy crude for U.S. refining.

  • Regulatory Compliance: All reports were filed with the U.S. State and Energy Departments within the 10-day post-execution window required by GL 47.

  • Zero Interdiction: The vessel transited the blockade zone without incident, maintaining a 100% transparent AIS track.

"SanctionedShipping.com didn't just read the licenses; they operationalized them. They bridged the gap between our legal team's requirements and the reality of the U.S. Navy's presence in the Caribbean."

— VP of Supply & Trading, U.S. Energy Major

2026 Venezuela Compliance Matrix

RequirementStatusSanctionedShipping.com ActionEstablished U.S. EntityVerifiedConfirmed entity formation prior to Jan 29, 2025.Choice of LawCompliantMandatory U.S. Governing Law Rider applied.Diluent ProvenanceCertifiedVerified U.S.-origin for GL 47 eligibility.Blockade StatusClearedPre-notified JTF Southern Spear for safe passage.

Navigate the "New Venezuela" with Confidence

The January 2026 transition has opened doors, but the Navy is still guarding the porch. Ensure your voyage is a "White-Channel" operation.

[Button: Request a Venezuela GL Audit]