Venezuela Sanctions Lawyer

Quick Answer: US sanctions on Venezuela remain comprehensive as of 2026, governed primarily by Executive Order 13884. The Government of Venezuela, PDVSA, and hundreds of named individuals — including Nicolás Maduro and his associates — remain on OFAC’s Specially Designated Nationals (SDN) list. While the Trump administration issued several new General Licenses in early 2026 easing certain oil and energy sector activities, the core sanctions framework is still in force. Any business or individual with Venezuela-related exposure needs expert legal guidance before transacting.

Overview of US OFAC Sanctions on Venezuela

The United States has maintained and progressively tightened economic sanctions against Venezuela since 2015. What began as targeted designations of corrupt officials evolved into a comprehensive sanctions regime following Executive Order 13884, signed in August 2019. Under EO 13884, all property and interests in property of the Government of Venezuela subject to US jurisdiction are blocked — effectively cutting off the Maduro-era state apparatus from the US financial system.

Venezuela sanctions sit within OFAC’s broader enforcement framework as one of the most active and frequently updated sanctions programs. With dozens of general licenses, frequent SDN list amendments, and major policy shifts under successive US administrations, the Venezuela program presents one of the most complex compliance challenges in international trade law today.

Our Venezuela sanctions program overview provides background on how the program developed. This page focuses on the legal services our firm provides to businesses, financial institutions, and individuals navigating Venezuela OFAC compliance.

Key Sanctions Programs Targeting Venezuela

Executive Order 13884 — Comprehensive Blocking Sanctions

EO 13884 (August 5, 2019) is the cornerstone of the US Venezuela sanctions regime. It blocks all property and interests in property of the Government of Venezuela within US jurisdiction or controlled by US persons. “Government of Venezuela” is defined broadly to include the state, government, political subdivisions, agencies, instrumentalities, and entities majority-owned by the government — including PDVSA and the Central Bank of Venezuela.

The order also prohibits US persons from engaging in transactions with or for the benefit of the Government of Venezuela unless authorized by OFAC via a General License or specific license. Violations carry severe civil and criminal penalties.

PDVSA and Oil Sector Sanctions

Petróleos de Venezuela, S.A. (PDVSA) — Venezuela’s state oil company — was designated by OFAC in January 2019. As the world’s fourth-largest oil reserve holder and the backbone of Venezuela’s economy, PDVSA sanctions have profound implications for global energy markets and for any company in the oil, gas, petrochemicals, or shipping sectors.

PDVSA and its majority-owned subsidiaries are blocked entities. Transactions with them require specific OFAC authorization. Key subsidiaries, trading companies, and shipping vessels associated with PDVSA have also been designated and added to the SDN list over the years.

SDN Designations — Maduro and Associates

Nicolás Maduro was personally designated under the Venezuela Sanctions Regulations in 2017. Hundreds of Venezuelan government officials, military figures, judges, businesspeople, and their family members have been added to OFAC’s SDN list. US persons are prohibited from dealing with SDNs regardless of the nature of the transaction — even seemingly benign commercial dealings can constitute violations if an SDN is involved.

Notable designees include senior military officials, National Constituent Assembly members, Venezuelan Supreme Court magistrates, and businesspeople linked to corruption. OFAC has also used counter-narcotics and counter-terrorism authorities to designate Venezuelan officials connected to drug trafficking and support for designated foreign terrorist organizations.

What Is Prohibited Under Venezuela Sanctions

Available General Licenses for Venezuela

OFAC has issued more than 50 General Licenses (GLs) for Venezuela, creating a complex patchwork of authorized activities. These GLs do not lift sanctions — they create narrow exceptions to the broad prohibitions. General Licenses are revocable at any time and must be interpreted carefully. Key GLs include:

• GL 4C — Authorizes exports and re-exports to Venezuela of agricultural commodities, medicine, medical devices, and certain related services.
• GL 20 — Authorizes transactions related to telecommunications and internet services in Venezuela.
• GL 31 — Covers certain transactions related to Venezuelan sovereign and PDVSA bonds.
• GL 40 — Covers personal remittances to Venezuela and certain family support transactions.
• GL 46 / 46B — Issued January–March 2026, authorizes established US entities to engage in Venezuelan oil trading, imports, exports, transport, and petrochemical transactions with PDVSA and its subsidiaries. Excludes exploration and production. Requires entity establishment on or before January 29, 2025.
• GL 52 — Issued March 2026, provides broad authorization for all transactions with PDVSA and majority-owned subsidiaries for energy sector activities. The most expansive PDVSA authorization to date.
• GL 5V — Issued March 2026, authorizes transactions related to PDVSA 2020 8.5% bonds on or after May 5, 2026.

Relying on a General License without expert legal review is risky. Each GL contains specific conditions, exclusions, and definitions that must be met. Our OFAC licensing attorneys provide detailed GL analysis and help clients structure transactions to qualify for available authorizations.

Recent Changes: Trump Administration Venezuela Policy (2025–2026)

Venezuela sanctions have undergone significant shifts under the Trump administration. Understanding these changes is essential for any business with Venezuela exposure.

Late 2025: Continued Tightening

Through December 2025, the Trump administration continued to expand the Venezuela SDN list, targeting Maduro associates and using counter-narcotics authorities against Venezuelan government-linked figures involved in drug trafficking. OFAC issued advisories warning financial institutions of evasion tactics used by Venezuelan entities.

January 2026: EO 14373 and Major Easing

A significant policy shift occurred in January 2026 following US government actions regarding the Venezuelan political situation. Executive Order 14373 (January 9, 2026) restructured aspects of Venezuela sanctions policy. OFAC issued General License 46 on January 29, 2026, authorizing established US companies to engage in Venezuelan oil trading — the most significant easing of PDVSA-related restrictions since sanctions were first imposed.

March 2026: Expansion and Clarification

OFAC rapidly expanded the energy sector authorizations in March 2026. GL 46B superseded GL 46 and extended coverage to petrochemicals. GL 52 provided broad authorization for PDVSA transactions. New FAQs clarified the scope of permissible activities. Simultaneously, OFAC conducted targeted SDN list removals and issued a March 31, 2026 advisory warning against sham transactions and evasion schemes.

Critical note for businesses: These General Licenses are revocable at any time. Venezuela sanctions policy remains highly dynamic. Any company relying on recent GL authorizations for Venezuela business must monitor OFAC guidance continuously and retain legal counsel to stay current.

Who Needs a Venezuela Sanctions Lawyer

The complexity of Venezuela’s sanctions framework means that a wide range of businesses and individuals require specialized legal counsel:

Oil and Energy Companies

Any company trading Venezuelan crude, refined products, or petrochemicals — or providing services to PDVSA — must navigate GL 46B and GL 52 conditions. Questions of entity eligibility, exclusions for exploration and production, third-country involvement, and counterparty SDN screening require expert analysis. The stakes are high: PDVSA-related enforcement actions have produced some of OFAC’s largest penalties in history.

Financial Institutions and Banks

Banks processing payments involving Venezuelan government entities, PDVSA, or Venezuelan counterparties face complex screening obligations. Correspondent banking relationships, trade finance, and investment banking activities all carry Venezuela sanctions risk. Financial institutions need robust compliance programs, customer due diligence protocols, and clear escalation procedures.

Exporters and Importers

US and non-US companies exporting goods to Venezuela or importing Venezuelan-origin products must assess whether their activities are covered by available GLs or require a specific OFAC license. Agricultural and medical exporters, technology companies, and shipping firms all face Venezuela-specific compliance obligations.

Investors and Private Equity

Investment in Venezuelan companies, assets, or sovereign debt triggers the Venezuela Sanctions Regulations. Even indirect investment through funds or holding structures with Venezuelan exposure requires careful legal review. Bond transactions, debt restructuring, and asset recovery proceedings involving Venezuelan government entities require OFAC authorization analysis.

Non-US Companies (Secondary Sanctions Risk)

Foreign companies not subject to primary US jurisdiction can still face secondary sanctions exposure if they provide material support to the Venezuelan government, deal with SDN-listed entities, or route transactions through the US financial system. Non-US energy companies dealing with PDVSA face particular risk and increasingly seek US legal counsel to assess their exposure.

Individuals with Venezuela Connections

US persons with Venezuelan business connections, family remittances, or real estate interests need to ensure their activities fall within authorized parameters. Venezuelan nationals with US assets or accounts may also need OFAC compliance guidance.

How Our Venezuela Sanctions Lawyers Help

Our team of OFAC sanctions attorneys brings deep expertise in Venezuela sanctions compliance and enforcement defense. We provide:

• General License analysis — Determining whether your contemplated transactions qualify under existing GLs, including the new GL 46B and GL 52 energy sector authorizations.
• Specific license applications — Preparing and submitting OFAC specific license applications for transactions not covered by existing GLs, including detailed legal memoranda and supporting documentation.
• SDN screening and counterparty due diligence — Advising on screening protocols for Venezuelan counterparties, beneficial ownership analysis, and identifying hidden SDN exposure through ownership chains.
• Compliance program design — Building or reviewing Venezuela sanctions compliance policies, procedures, and training programs for financial institutions, energy companies, and multinational corporations.
• Enforcement defense — Representing clients in OFAC investigations, responding to subpoenas, preparing voluntary self-disclosures, and negotiating civil settlements and no-action outcomes.
• Transaction structuring — Advising on how to structure Venezuela-related transactions to minimize sanctions risk while achieving commercial objectives.
• Real-time policy monitoring — Providing ongoing updates as OFAC amends GLs, adds or removes SDN designations, and issues new guidance on the Venezuela program.

Venezuela sanctions present some of the most dynamic and consequential compliance challenges in international trade law today. Whether you are a US oil trader seeking to leverage new GL 52 authorizations, a foreign bank assessing secondary sanctions exposure, or a company facing an OFAC investigation, our Venezuela sanctions lawyers provide the strategic legal counsel you need.

Contact us today for a confidential consultation. Our Venezuela sanctions attorneys are available to assess your exposure and advise on compliant transaction structures.