Venezuela Sanctions
Quick Answer
Venezuela sanctions are U.S. economic measures administered by OFAC under Executive Orders 13692, 13808, 13827, and 13884, targeting the Venezuelan government, PDVSA, corrupt officials, and key sectors including oil, gold, and finance. In early 2026, following major political changes, the U.S. issued broad General Licenses significantly easing oil and mining restrictions while SDN designations for corrupt actors remain active.
Overview of US Sanctions on Venezuela
The United States has maintained a comprehensive sanctions regime against Venezuela since 2005, steadily expanding its scope in response to political repression, human rights abuses, corruption, and the consolidation of authoritarian rule under Nicolás Maduro. Administered by the Office of Foreign Assets Control (OFAC) under the authority of the Venezuela Sanctions Regulations (31 CFR Part 591), US sanctions on Venezuela target the Venezuelan government, state-owned enterprises (particularly PDVSA), senior officials, and sectors including oil, gold, and finance.
The Venezuela OFAC sanctions regime underwent a significant transformation in early 2026, following political changes in Venezuela. The U.S. issued a new Executive Order and over 15 General Licenses substantially easing restrictions on the oil, gas, and mining sectors — while maintaining SDN designations for corrupt officials and entities. Understanding the current state of Venezuela sanctions 2026 requires navigating a complex landscape of active executive orders, sectoral restrictions, and authorized exceptions.
Timeline of US Sanctions on Venezuela
| Date | Action | Key Provisions |
|---|---|---|
| 2005 | First targeted sanctions | Drug trafficking and criminal activity designations |
| March 2015 | Executive Order 13692 | Declared Venezuela a national security threat; targeted SDN sanctions for human rights abusers and corrupt officials |
| August 2017 | Executive Order 13808 | Prohibited dealings in Venezuelan debt/equity; restricted oil sector financial transactions |
| March 2018 | Executive Order 13827 | Prohibited transactions involving Venezuelan cryptocurrency (Petro) |
| November 2018 | Executive Order 13850 | Targeted gold sector; authorized sanctions on any sector of Venezuelan economy |
| January 2019 | PDVSA SDN Designation | Venezuela’s state oil company placed on SDN list; all U.S. person transactions prohibited without OFAC license |
| August 2019 | Executive Order 13884 | Blocked all Venezuelan Government property; broadened sanctions to cover entire government |
| 2021–2024 | Conditional relief attempts | Temporary licenses for specific sectors tied to electoral process commitments (Chevron GL 41 series) |
| January 3, 2026 | Political transition | Maduro removed from power; U.S. begins broad sanctions relief |
| January 9, 2026 | Executive Order 14373 | New national emergency declaration; protects Venezuelan oil revenues in U.S. Treasury-held funds; requires payments to blocked entities into these accounts |
| January–March 2026 | Series of General Licenses (GL 46–GL 55) | Broad authorization for oil, gas, mining, and related sectors; full PDVSA unblock via GL 52 |
Active OFAC Executive Orders on Venezuela
The following Executive Orders form the legal foundation of the OFAC Venezuela sanctions regime. While 2026 General Licenses have substantially narrowed the effective prohibitions, these Executive Orders remain legally in force:
- EO 13692 (March 2015) — Authorizes SDN sanctions on persons responsible for undermining democracy, human rights abuses, or corruption in Venezuela. Remains the primary authority for individual designations of Venezuelan officials.
- EO 13808 (August 2017) — Prohibits dealings in Venezuelan government debt and PDVSA equity. Largely superseded by 2026 General Licenses for oil sector activity, but the underlying restrictions remain in force.
- EO 13827 (March 2018) — Blocks any transaction involving Venezuela’s state-backed cryptocurrency, the Petro (Petromoneda). Still fully in force.
- EO 13884 (August 2019) — The broadest executive order, blocking all property of the Government of Venezuela within U.S. jurisdiction. General License 52 (March 2026) now authorizes most PDVSA transactions previously blocked under this order.
- EO 14373 (January 2026) — New emergency declaration. Establishes a mechanism to protect Venezuelan oil revenues held in U.S. Treasury accounts from attachment and execution, while requiring that payments to blocked entities be channeled through these Treasury-held accounts.
Key Restricted Sectors Under Venezuela OFAC Sanctions
| Sector | Core Restrictions | 2026 General License Authorizations | Status |
|---|---|---|---|
| Oil & Gas (PDVSA) | All PDVSA transactions blocked; no new debt/equity dealings under EO 13808 | GL 46B: Venezuelan oil trade; GL 48A: Exploration/production services; GL 52: All PDVSA transactions authorized | Substantially eased — most activity now authorized |
| Gold & Mining | EO 13850/13884 block corrupt operators misappropriating Venezuelan resources | GL 51A, GL 54, GL 55: Mining sector opened to non-corrupt Western firms | Conditionally eased |
| Financial Sector | Venezuelan government debt/equity banned (EO 13808); payments to blocked persons restricted | GL 4C: Agricultural/medical exports; EO 14373: Payments into Treasury-held accounts authorized | Mostly restricted; humanitarian exceptions exist |
| Venezuelan Petro Cryptocurrency | All transactions with Petro cryptocurrency prohibited (EO 13827) | No general license; specific license required | Fully restricted |
| Defense & Arms | SDN blocks on Venezuelan government arms dealings; arms embargo in effect | No broad authorizations; case-by-case specific licenses only | Fully restricted |
| Individual SDN Designees | All transactions prohibited; assets frozen; U.S. entry banned | No general license covers SDN individuals | Fully restricted |
PDVSA and Venezuela Oil Sanctions
The designation of Petróleos de Venezuela, S.A. (PDVSA) on the SDN list in January 2019 was the single most impactful element of the Venezuela sanctions regime. As Venezuela’s state oil company and primary source of government revenue, PDVSA’s designation effectively severed its access to U.S. financial markets, halted U.S. imports of Venezuelan crude oil, and froze PDVSA’s U.S.-based assets — including its CITGO subsidiary.
In 2026, OFAC issued General License 52 (March 18, 2026), which authorizes all transactions with PDVSA and its majority-owned subsidiaries that were previously prohibited under EO 13884. This represents the most significant easing of Venezuela-related oil sanctions since PDVSA’s designation. However, GL 52 does not remove PDVSA from the SDN list — the designation remains in effect, and any activity not explicitly covered by GL 52 or other GLs continues to require a specific OFAC license.
Doing Business in Venezuela Legally
For companies considering operations in Venezuela, the current regulatory framework allows more activity than at any point since 2019 — but compliance remains essential. Key steps for legal engagement with Venezuela in 2026:
- Screen all counterparties against the OFAC SDN list before any transaction. Individual SDN designees remain fully blocked regardless of sector-wide General Licenses
- Verify General License coverage for your specific activity. GL 46B, GL 47, GL 48A, GL 52, and the mining GLs (51A, 54, 55) cover most energy and mining activity — but conditions apply, and gaps exist
- Avoid prohibited partners — GLs explicitly exclude joint ventures with entities from Russia, Iran, China, Cuba, or North Korea
- Use Treasury-designated accounts for any payments to blocked entities (as required by EO 14373)
- Maintain records of all compliance steps, including SDN screening documentation, license reliance analysis, and transaction records
Violations of Venezuela OFAC sanctions carry severe penalties: civil fines of up to $1 million per violation or twice the value of the transaction (whichever is greater), and criminal penalties of up to $1 million and 20 years imprisonment for willful violations. Strict liability means that even unintentional violations can result in civil penalties — making expert OFAC legal counsel essential for any company operating in or with Venezuelan counterparties.
Venezuela Sanctions General Licenses (Key Active Authorizations)
| General License | Effective Date | Authorization |
|---|---|---|
| GL 46B | March 13, 2026 | Authorizes U.S. persons to engage in transactions involving Venezuelan-origin petroleum products, including lifting, export, and sale |
| GL 47 | February 3, 2026 | Authorizes export of U.S.-origin diluents (including naphtha) to Venezuela for oil production |
| GL 48A | March 13, 2026 | Authorizes goods, services, and technology for oil and gas exploration, production, and related activities in Venezuela |
| GL 52 | March 18, 2026 | Authorizes all transactions with PDVSA and its majority-owned subsidiaries previously blocked under EO 13884 — the most comprehensive Venezuela oil authorization to date |
| GL 51A | Early 2026 | Authorizes specific mining sector transactions with non-corrupt Venezuelan entities |
| GL 54 / GL 55 | Early 2026 | Additional mining sector authorizations for Western firms operating outside corrupt structures |
| GL 4C | Active (2019+) | Authorizes exports of agricultural commodities, medicine, and medical devices to Venezuela |
| GL 5V | March 19, 2026 | Authorizes specific dealings in PDVSA bonds and related instruments post-May 5, 2026 |
Venezuela SDN Designations
Despite the broad 2026 easing of sectoral sanctions, OFAC’s SDN list continues to include approximately 150-200 Venezuela-related designations. These include:
- Senior Maduro-era government officials and their associates
- Operators in the gold and mining sectors accused of misappropriating Venezuelan resources
- Entities that facilitated sanctions evasion or corruption
- Military and intelligence officials linked to human rights abuses
Transactions with any SDN-listed individual or entity remain prohibited regardless of any General License, unless the license explicitly authorizes dealings with SDNs. If your Venezuelan business partner, counterparty, or investment target appears on the SDN list, you need to consult with sanctions lawyers specializing in SDN removal before proceeding.
How Sanctions Lawyers Can Help with Venezuela
Whether you are a company seeking to re-enter the Venezuelan market under the new General Licenses, an individual or entity designated on the SDN list in connection with Venezuela, or a financial institution processing transactions involving Venezuelan counterparties, experienced Venezuela sanctions legal counsel can help with:
- Assessing whether your planned activity is authorized under current GLs or requires a specific OFAC license
- Applying for specific licenses for activities not covered by General Licenses
- Challenging SDN designations related to Venezuela through administrative petitions
- Representing companies in OFAC enforcement investigations arising from pre-2026 Venezuela business activity
- Designing Venezuela-specific compliance programs and counterparty due diligence procedures
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Frequently Asked Questions
What are OFAC Venezuela sanctions?
OFAC Venezuela sanctions are U.S. economic and financial measures targeting the Maduro regime, key government officials, state-owned entities, and Venezuela’s oil sector. The sanctions include SDN designations of senior officials under Executive Orders 13692 and 13850, a broad embargo on the Venezuelan government’s dealings with U.S. persons, and sector-specific restrictions on PDVSA (the state oil company). U.S. persons are prohibited from trading Venezuelan sovereign debt and dealing with blocked Venezuelan government property without an OFAC license.
Is PDVSA subject to OFAC sanctions?
Yes. PDVSA (Petróleos de Venezuela, S.A.) is designated on the OFAC SDN list and is treated as blocked property of the Venezuelan government. U.S. persons are prohibited from purchasing Venezuelan oil from PDVSA, entering contracts with PDVSA, or processing PDVSA-related payments without a specific OFAC license. Non-U.S. companies that conduct significant transactions with PDVSA risk secondary sanctions designation. Our attorneys advise energy companies on compliance and license applications related to PDVSA transactions.
Can private Venezuelan companies trade with U.S. persons?
Private Venezuelan companies that are not owned or controlled by the Venezuelan government and are not individually designated on the SDN list can generally transact with U.S. persons. However, due diligence is essential — OFAC applies the 50-percent rule, meaning any Venezuelan company 50% or more owned by a designated person is itself blocked. Companies must also verify that transactions do not involve Venezuelan government entities, PDVSA subsidiaries, or sanctioned individuals. Our attorneys provide Venezuelan counterparty screening and compliance opinions.
What OFAC general licenses apply to Venezuela?
OFAC has issued several general licenses for Venezuela covering: certain activities by U.S. persons in Venezuela (GL 3), transactions related to personal remittances (GL 4), official U.S. government activities (GL 1), transactions related to the provision of emergency medical services (GL 2), and specific petroleum-related transactions authorized periodically. The scope and conditions of these licenses change with U.S. policy toward Venezuela. Our attorneys provide up-to-date analysis of applicable Venezuela general licenses for your specific transaction.
Can I be sanctioned for doing business with Venezuela?
U.S. persons face civil and criminal liability for dealing with blocked Venezuelan government property, transacting with SDN-designated officials, or purchasing Venezuelan oil from PDVSA without a license. Non-U.S. persons conducting significant transactions with PDVSA or other sanctioned Venezuelan entities may face secondary sanctions under Executive Order 13850. Our attorneys assess sanctions exposure for both U.S. and foreign companies involved in Venezuela-related business and design compliance structures to minimize risk.