Compliance Landscape in Venezuela Following Nicolas Maduro’s Removal from Power

While the recent apprehension of Nicolás Maduro signals a potential shift in US-Venezuela relations, foundational sanctions on Venezuela remain intact. Companies should continue to prioritize compliance, as the US Treasury Department continues to maintain restrictions pending any formal amendment to the sanctions.

The removal from power of Nicolás Maduro by the United States on January 3, 2026 may be the beginning of a sea change in the relationship between the United States and Venezuela. Many US and Venezuelan businesses and people are hopeful for a growth of commerce, particularly a redevelopment of Venezuela’s oil and gas sector. However, as of the date of this LawFlash, the remaining leadership of Maduro’s government along with the US blocking sanctions on that government remain in place. As a result, the initial excitement around potential opportunities identified with Maduro’s arrest is now tempered by the reality that significant trade restrictions, among other legal, security, and logistical challenges, remain in place and complicate efforts to develop business.

OVERVIEW OF SANCTIONS ON VENEZUELA

Since 2015, the United States has employed an evolving array of targeted and sectoral sanctions against Venezuela’s government under Maduro, initially in response to political oppression, human rights abuses, and corruption under the government. While these sanctions are primarily list-based and not comprehensive territorial sanctions (such as those imposed on Cuba, Iran, and North Korea), the Trump-Pence administration enhanced the Venezuela Sanctions Program, broadening restrictions to activities involving the government of Venezuela (GoV) as a whole. While certain sanctions on the GoV temporarily relaxed under the Biden administration, Maduro’s unwillingness to comply with US conditions attached to sanctions relief resulted in a rapid snap-back of the prior sanctions restrictions under the current US administration.

The Evolution of Venezuela Economic Sanctions

In response to repression by Maduro’s government, the US Congress enacted the Venezuela Defense of Human Rights and Civil Society Act of 2014, which required the president “to impose sanctions on people the President identified as responsible for significant acts of violence, serious human rights abuses, or antidemocratic actions.”

In March 2015, President Barack Obama issued Executive Order (EO) 13692, implementing this congressional mandate. EO 13692 imposed list-based sanctions, authorizing the US Department of the Treasury Office of Foreign Assets Control (OFAC), which administers and enforces US economic sanctions, to impose sanctions against individuals and entities determined to be involved in undermining democratic processes, human rights abuses, and public corruption. Since then, OFAC has designated more than 150 persons and entities pursuant to EO 13692, including Maduro, his wife and son, Venezuelan Vice-President Delcy Rodriguez—who was recently sworn in as interim president pursuant to a ruling by Venezuela’s Supreme Court—and Venezuelan Defense Minister Vladimir Padrino López.

In 2017, President Donald Trump issued additional EOs further restricting transactions involving Maduro’s government. EO 13808, issued in August 2017, imposed certain limited sanctions on Petróleos de Venezuela, S.A. (PdVSA), Venezuela’s state-owned oil and gas company and a critical part of Venezuela’s economy. In January 2019, President Trump issued EO imposing blocking sanctions on on PdVSA and listing it as a Specially Designated National and Blocked Person (SDN). This action blocked PdVSA’s assets in the United States and prohibited US persons from most dealings involving the company and any entity it owned fifty percent or more.[1]

The US again broadened sanctions in August 2019. EO 13884 blocked all property of the Government of Venezuela and prohibited US persons from engaging in any transactions directly or indirectly with the government without authorization from OFAC.

EO 13884 broadly defines “Government of Venezuela” to include

• the state and Government of Venezuela; any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petróleos de Venezuela, S.A. (PdVSA);
• any person or entity owned or controlled, directly or indirectly, by the foregoing; and
• any person who has acted or purported to act directly or indirectly for or on behalf of, any of the foregoing, including as a member of the Maduro regime.

Outside of the authorizations of limited general licenses, US persons may not deal directly or indirectly with any Venezuelan government official or entity, regardless of whether they are on the SDN List.

Temporary Sanctions Relief to Induce Government Cooperation

In November 2022, to incentivize the Maduro administration’s participation with the Venezuelan opposition, the Biden administration relaxed certain sanctions, including allowing Chevron to resume oil production and import and export through its joint ventures with PdVSA. As negotiations continued, in 2024, the United States more broadly authorized transactions involving the oil and gas sector by any company for a six-month term, as well as transactions with Minerven, the state-owned mining company.

However, following a Venezuelan Supreme Court decision to ban the opposition’s candidate, Maria Corina Machado, OFAC revoked the license authorizing transactions with Minerven and declined to renew the license broadly authorizing oil and gas transactions. In March 2025, OFAC amended the Chevron license to authorize a wind-down of its activities, effectively reimposing the prior sanctions.

Prior to the recent action to capture Maduro, the administration also established a blockade to target sanctioned Venezuelan oil tankers and prevent their entry into and departure from Venezuela.

CURRENT STATUS IN VENEZUELA

Despite the removal of Maduro from power, companies would be well advised to exercise caution. Notably, the US government has left in power the remaining leadership of the Maduro administration, including multiple SDNs with whom US persons are prohibited from dealing, absent OFAC authorization. All Venezuela sanctions remain in place, including those prohibiting transactions and activities involving the GoV, PdVSA, Minerven, and the oil and gas sector.

Since January 6, 2026, the president and US administration officials have made a number of statements regarding the export of oil and other business activities in Venezuela, including the following:

• Venezuela will provide between 30 million and 50 million barrels of oil to the United States for sale at market prices.
• The United States will not authorize the production of oil in Venezuela unless Venezuela severs economic ties with China, Russia, Iran, and Cuba and agrees to partner exclusively with the United States on oil production and favor the United States when selling oil.

On January 7, 2026, the White House announced that the secretary of energy is implementing a deal to acquire Venezuelan oil and transport it to the United States for sale. As part of this process, the administration stated that the United States would begin to selectively roll back sanctions to enable these activities. The United States will also authorize the import into Venezuela of oil field equipment, parts, and services to facilitate the modernization and expansion of Venezuela’s oil production capabilities. These activities will necessarily involve commodity dealers, financial institutions, oil and gas service companies, and transportation, among others.

KEY TAKEAWAYS

New investment and business activities in Venezuela require caution. Real changes in applicable legal requirements need to occur before companies can comfortably take action. In similar circumstances in the past, the government has successfully acted against persons (through OFAC enforcement or otherwise) who have “jumped the gun” on the lifting of sanctions by reacting to statements by public officials that previewed—but did not themselves effect—the necessary regulatory changes.

While the administration’s public statements indicate a relaxation of sanctions, particularly related to oil and gas production and related activities, all sanctions remain in place, including those targeting PdVSA, the GoV, and the oil and gas sector. Until OFAC issues changes (e.g., through new general licenses), there are no legal permissions to engage in such activities, and parties doing so without OFAC authorization risk significant financial penalties.

If sanctions are relaxed, we could expect temporary authorizations such as those used in 2022 to incentivize the Venezuelan government’s participation in negotiations with the opposition. However, given the failure of that approach previously, the administration may more strictly limit when and how Venezuelan oil and gas activities resume. Given the conditions demanded about severing economic ties with US adversaries and providing exclusive access to US markets, the administration may consider delaying relaxation of sanctions until the Venezuelan government provides evidence of its cooperation and takes steps to meet those demands.

As the US oil industry is aware, doing business in Venezuela comes with risk given the current political and economic situation and the added expense associated with extracting the type of crude that Venezuela produces. Venezuela’s oil production for export remains severely depressed due to a lack of investment, maintenance, and repair, among other challenges. Depending on how the situation unfolds, ongoing political instability and security conditions may continue to pose material risks for US participants operating in Venezuela.

STAY INFORMED

Our team continues to monitor this developing situation closely. Stay tuned for our upcoming Venezuela resource center for more information and to receive updates.

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