HomeVenezuela & PDVSA Sanctions
OFAC Venezuela sanctions were imposed by the U.S. government in response to the deep political and economic crisis in the country. They block the Government of Venezuela and the state oil company PdVSA, freeze the U.S. assets of designated officials and companies, and restrict dealings with Venezuela’s oil, gold and financial sectors. Venezuela is not under a full trade embargo, and since January 2026 OFAC has opened large parts of the oil, mining and banking sectors through general licenses — on strict conditions.
If a payment, contract or shipment with a Venezuelan link has been blocked, or you need to know whether a deal falls within a general license, our OFAC sanctions programs team can review it and prepare the filing OFAC requires.
- Venezuela & PDVSA Sanctions
- Is Venezuela Sanctioned by the U.S.?
- What Changed in 2026
- What U.S. Persons Cannot Do
- Risks for Non-U.S. Companies and Banks
- Current Venezuela General Licenses
- PdVSA and the Oil Sector
- Trade and Export Restrictions
- Bank Accounts and Transfers With a Venezuelan Link
- How Our Venezuela Sanctions Lawyers Help
- FAQ
Is Venezuela Sanctioned by the U.S.?
Yes — but Venezuela is not under a comprehensive embargo like Cuba, Iran or North Korea. The U.S. program is built on a series of executive orders issued since 2015 and is administered by the Treasury’s Office of Foreign Assets Control (OFAC) under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. Its core is Executive Order 13884 (August 5, 2019), which blocks all property and interests in property of the Government of Venezuela that are in the United States or in the possession or control of a U.S. person. The “Government of Venezuela” is defined broadly: it includes state agencies, the Central Bank and state-owned companies such as Petróleos de Venezuela, S.A. (PdVSA), and any entity they own or control.
In practice this means that:
- U.S. persons may not deal with the Government of Venezuela, PdVSA or any other blocked person unless a general or specific license from OFAC authorizes it
- individuals and companies on the SDN List under the Venezuela program have their U.S.-linked assets frozen
- entities owned 50 percent or more by blocked persons are blocked as well, even if they are not named
- ordinary dealings with private Venezuelan individuals and companies that are not blocked and not owned by the government are not prohibited — but banks screen them closely
Venezuela is one of the programs OFAC adjusts most often. The sections below reflect the program as published by OFAC at the end of October 2026; general licenses are amended frequently, so the current text of any license must be checked before a transaction.
What Changed in 2026
After U.S. forces detained Nicolás Maduro in Caracas on January 3, 2026, as widely reported, and Delcy Rodríguez took office as acting president, U.S. policy shifted from maximum pressure to tightly conditioned re-engagement. The sanctions architecture was not dismantled — the Government of Venezuela and PdVSA remain blocked — but OFAC began issuing general licenses that authorize specific activity:
| Date (2026) | Measure | What it means |
|---|---|---|
| January 9 | E.O. 14373, “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People” | Shields the Foreign Government Deposit Funds — Treasury-held proceeds of Venezuelan natural-resource and diluent sales — from attachment and other judicial process; later licenses require payments to Venezuelan state parties to go into these funds |
| January 29 – February 13 | General Licenses 46 (oil), 47 (U.S.-origin diluents), 48 (goods and services for oil, gas and electricity), 49 (contingent investment contracts) and 50 (operations of named companies) | First authorizations for oil-sector activity; only GL 46 is limited to “established U.S. entities” |
| March 18 | General License 52 | Authorizes most transactions with PdVSA and its 50%-owned entities for established U.S. entities, with exclusions for PdVSA bonds and other debt, sales or pledges of state-held equity, enforcement of judgments against blocked property, and any change to the governance of PDV Holding, CITGO Holding or CITGO Petroleum |
| March | General Licenses 51, 54 and 55 | Open the minerals sector, including gold: purchases and exports, supply of services to mining operations, and contingent investment contracts |
| April 1 | SDN removal | OFAC removed acting president Delcy Rodríguez from the SDN List |
| April 14 | General Licenses 56 and 57 | Allow negotiation of contingent commercial contracts with the Government of Venezuela, and financial services involving Banco Central de Venezuela, Banco de Venezuela, Banco del Tesoro and Banco Digital de los Trabajadores |
| May–October | General Licenses 58 to 62 and amended versions of earlier licenses | Debt-restructuring services, telecommunications, aviation-related supplies and earthquake relief; later amendments widened dispute-resolution options and broadened the oil, mining and PdVSA licenses |
Most 2026 licenses share common conditions, but they differ in detail. GLs 46E, 51D and 52C are limited to an “established U.S. entity” — one organized under U.S. law on or before January 29, 2025; the others are available to U.S. persons generally. Where a license requires it, payments to blocked Venezuelan parties (other than local taxes, permits and fees) must go into the Foreign Government Deposit Funds or another account the Treasury designates, and contracts with Venezuelan state parties must provide for dispute resolution in the United States, the United Kingdom, France or Singapore. The licenses exclude payment terms that are not commercially reasonable, debt swaps, payments in gold and Venezuelan digital currency, blocked vessels, and parties in Russia, Iran, North Korea or Cuba; several also exclude any person in China, others only Venezuelan or U.S. entities owned by or in a joint venture with Chinese persons. Most operational licenses require reports to the State Department and the Department of Energy or the Interior.
Handling Venezuela Sanctions
From oil, mining and banking general licenses to frozen payments and SDN listings — we check how the 2026 rules apply to your transaction.
Legal AssistanceWhat U.S. Persons Cannot Do
U.S. citizens and permanent residents, companies organized under U.S. law, and anyone in the United States must comply. Without a general license that clearly covers the activity, or a specific license, they may not:
- enter into contracts, make payments or provide services to the Government of Venezuela, PdVSA or entities they own or control (E.O. 13884, E.O. 13850)
- deal with individuals and companies designated on the SDN List under the Venezuela program, or with property in which they have an interest
- deal in new debt or new equity of the Government of Venezuela or PdVSA, or buy debt owed to the Government (E.O. 13808, E.O. 13835); existing bonds may be traded only as General Licenses 3I, 9H and 5Z allow, and never sold to a blocked person
- transact in any digital currency issued by or for the Government of Venezuela, including the “petro” (E.O. 13827)
- engage in any transaction that evades or avoids these prohibitions, causes a violation, or conspires to violate them
Contingent contracts are a common trap. General Licenses 49B, 55A and 62 allow negotiating and signing contracts whose performance is expressly contingent on separate OFAC authorization; General License 56 allows only negotiations — both signing and performance of a contract with the Government of Venezuela need separate OFAC authorization. Civil penalties for violations under IEEPA reach $377,700 per violation or twice the value of the transaction, whichever is greater; willful violations carry criminal fines of up to $1 million and up to 20 years in prison.
Risks for Non-U.S. Companies and Banks
Foreign companies are not bound by the U.S. prohibitions directly, but the Venezuela program reaches them in two ways. First, E.O. 13850 and E.O. 13884 allow the Treasury to designate any person that operates in sectors of the Venezuelan economy identified by the Secretary — oil and gold among them — or that materially assists the Government of Venezuela or a blocked person. Second, a U.S. dollar payment, U.S. bank or U.S. service provider in the chain can bring the transaction within U.S. jurisdiction, and a non-U.S. person that causes a U.S. person to violate the sanctions can itself face civil penalties under IEEPA.
In FAQ 1247 (March 31, 2026, updated September 2, 2026), OFAC said that non-U.S. persons would not face sanctions exposure for activity of the kind authorized by General Licenses 46, 51 and 52 if they meet comparable conditions: the company was organized in a third country on or before January 29, 2025, payments go into the designated Treasury accounts, terms are commercially reasonable, and no Russia-, Iran-, North Korea-, Cuba- or China-linked parties or blocked vessels are involved. Outside these conditions the designation risk remains.
Foreign banks should note that GL 57 authorizes U.S. persons to provide financial services to or for four state banks (including the Central Bank) and to individuals blocked only because they are part of the Government of Venezuela, including its employees, who are not on the SDN List — but anti-money-laundering and correspondent-bank due diligence still apply, and many banks keep restrictive policies of their own.
Current Venezuela General Licenses
OFAC publishes all Venezuela licenses on its Venezuela-Related Sanctions page. The main current licenses are listed below; letters after the number show the latest amendment.
| License | OFAC title (summary) | Key point |
|---|---|---|
| GL 46E | Certain activities involving Venezuelan-origin oil or petrochemical products | Lifting, export, sale, storage and transport, including refining; established U.S. entities |
| GL 47B | Sale of U.S.-origin diluents to Venezuela | Supply of diluents needed to move heavy crude |
| GL 48D | Supply of certain items and services to Venezuela | Goods, technology, software and services for oil, gas, petrochemical and electricity operations |
| GL 49B | Contingent contracts for certain investment in Venezuela | Negotiating and signing only; performance needs separate OFAC authorization; open to all U.S. persons; any China involvement excluded |
| GL 50C | Oil or gas sector operations of certain entities | Operations in Venezuela of BP, Chevron, Eni, Maurel & Prom, Repsol and Shell |
| GL 51D | Venezuelan-origin coal or minerals, including gold | Purchase, export, sale and transport by established U.S. entities; mining and processing in Venezuela not covered; reports to State and Interior every 30 days |
| GL 52C | Certain transactions involving PdVSA | Broad dealings with PdVSA for established U.S. entities; PdVSA bonds, debt and equity excluded |
| GL 54C / 55A | Coal and minerals operations; contingent investment contracts | Services to mining operations; investment contracts contingent on OFAC approval |
| GL 56 / 57 | Contingent commercial contracts with the Government of Venezuela; financial services with certain state banks | Negotiation across sectors; banking with BCV, Banco de Venezuela, Banco del Tesoro, Banco Digital de los Trabajadores |
| GL 24A, 30B, 59, 61A, 62 | Telecommunications and mail; port and airport operations; aviation-related supplies; telecom supplies and investment | Telecom, mail, ports and airports, Conviasa aircraft maintenance; GL 62 — contingent telecom investment contracts |
| GL 58 / 60A | Debt-restructuring advice to the Government; earthquake relief | 58: legal and financial advice only, no restructuring itself; 60A valid until April 21, 2027 |
| GL 5Z | PdVSA 2020 8.5 percent bond | Authorizes dealings in the PdVSA 2020 8.5% bond on or after November 5, 2026; OFAC has repeatedly postponed this date — check the latest version |
Older licenses that remain in force cover, among other things, U.S. persons’ accounts and personal remittances through certain banks (GL 16C), personal maintenance of U.S. persons living in Venezuela (GL 32), emergency medical services (GL 26), patents and trademarks (GL 27), certain dealings with CITGO-related entities (GLs 2A and 7C) and the secondary trading of certain bonds (GLs 3I and 9H). General Licenses 8O, 41 and 44A are no longer in force and should not be relied on.
Who counts as an “established U.S. entity”?
Under GLs 46E, 51D and 52C, an entity organized under U.S. law on or before January 29, 2025. Other 2026 licenses (for example 47B, 48D, 49B, 54C, 56 and 57) have no such cut-off date. Non-U.S. companies are not covered by any license, but OFAC’s FAQ 1247 describes when they face no sanctions exposure.
Where do payments to PdVSA or the Government go?
Into the Foreign Government Deposit Funds specified in E.O. 14373 or another account designated by the Treasury, except payments for local taxes, permits and fees. Paying a blocked Venezuelan party any other way takes the transaction outside the license.
What do the licenses not cover?
Unblocking property that is already blocked, transactions with blocked vessels or with persons separately designated on the SDN List, dealings involving Russia-, Iran-, North Korea-, Cuba- or China-linked parties, and — under GL 52 — PdVSA bonds and other debt, sales or pledges of state-held equity, and any change to the governance of PDV Holding, CITGO Holding or CITGO Petroleum. Anything outside a license still requires a specific OFAC license.
PdVSA and the Oil Sector
PdVSA has been on the SDN List since January 2019 (E.O. 13850) and is also blocked as part of the Government of Venezuela under E.O. 13884. General License 52 does not remove it from the list: it authorizes defined dealings by established U.S. entities, and everything else — including any deal by a company that does not meet the conditions — still needs OFAC authorization. Entities owned 50 percent or more by PdVSA are treated the same way.
For oil traders, refiners, shippers and service companies the practical questions are who may lift and sell Venezuelan crude, how payments must be routed, what has to be reported and when a contract can be performed. Our analysis of the March 2026 oil-sector general licenses covers these points in more detail.
Trade and Export Restrictions
Trade with Venezuela is regulated by two U.S. agencies. OFAC’s rules turn on the counterparty: selling to a private Venezuelan company that is not blocked or government-owned is not prohibited, while selling to a state entity, PdVSA or an SDN requires a license. Export controls administered by the Commerce Department’s Bureau of Industry and Security (BIS) turn on the item and its end use.
- Under the Export Administration Regulations (EAR), Venezuela is subject to the military end-use and end-user rule in 15 C.F.R. § 744.21: many items require a license if they are intended for the Venezuelan military or for a military end use, and such applications are reviewed with a presumption of denial
- Items listed in Supplement No. 2 to Part 744 require a license for any Venezuelan military end use or end user, so each export needs its own classification and end-use review
- Exports to parties on the BIS Entity List or the Military End-User List may require a license, and dealings with vessels designated by OFAC are prohibited
- Gold and other minerals are covered by both programs: E.O. 13850 targeted the gold sector, and General Licenses 51D, 54C and 55A now set the conditions for minerals trade
Because OFAC and BIS rules apply at the same time, a shipment can be lawful under one and still require a license under the other. Exporters should screen every party in the chain — buyer, consignee, end user, carrier and bank — before shipping.
Bank Accounts and Transfers With a Venezuelan Link
Even where a transaction is lawful, banks often freeze or return payments that mention Venezuela, a Venezuelan port or a state entity until they have reviewed the parties. If your account or a transfer has been stopped, the first step is to find out whether it was blocked or rejected and under which authority. We explain how this works for individuals and businesses in our guide to frozen accounts and transfers with a Venezuelan link.
How Our Venezuela Sanctions Lawyers Help
We advise companies, banks, traders and individuals in the United States, Latin America and Europe on the Venezuela program as it changes. Typical matters include:
- License analysis and applications — whether a deal fits General License 46E, 48D, 51D, 52C or 57, and preparing a specific license application when it does not
- Blocked and rejected payments — identifying why funds were stopped and requesting their release from OFAC
- SDN listings — reconsideration requests for individuals and companies designated under the Venezuela program; see SDN List removal
- Compliance programs — screening, ownership analysis, payment routing and reporting for companies re-entering the Venezuelan market; see OFAC compliance counsel
- Contract structuring — contingent contracts, governing-law clauses and wind-down planning in case a license is amended or revoked
Sources: OFAC, Venezuela-Related Sanctions; OFAC Venezuela FAQs; OFAC Recent Actions, April 14, 2026; 31 C.F.R. Part 591; 15 C.F.R. § 744.21; Federal Register, 91 FR 17672 (April 7, 2026).
FAQ
What are the current OFAC sanctions on Venezuela?
The Government of Venezuela, including PdVSA and the Central Bank, remains blocked under E.O. 13884, and a large number of individuals and companies remain on the SDN List under the Venezuela program. Since January 2026, OFAC has authorized defined activity in the oil, petrochemical, electricity, mining, banking and telecom sectors through general licenses with strict conditions. Anything outside those licenses still requires a specific license.
Is Venezuela sanctioned by the USA?
Yes. Venezuela is subject to a broad U.S. sanctions program, but not a full embargo: the government and state companies are blocked, designated persons are frozen out of the U.S. system, and certain sectors are restricted, while ordinary trade with private, non-blocked Venezuelans is not prohibited.
Are U.S. companies allowed to do business with Venezuela?
With private Venezuelan companies that are not blocked or government-owned, generally yes, subject to export controls. With the Government of Venezuela or PdVSA, only as far as a general license allows — the main oil, mining and PdVSA licenses (46E, 51D, 52C) are limited to companies organized in the U.S. on or before January 29, 2025, and many licenses require payments into Treasury-designated accounts — or with a specific license.
Has the U.S. lifted sanctions on Venezuela in 2026?
No. OFAC has eased sanctions through general licenses and removed some individuals from the SDN List, including acting president Delcy Rodríguez on April 1, 2026, but none of the Venezuela executive orders has been revoked and the licenses can be amended or withdrawn at any time.
Can I send money to family in Venezuela?
Personal remittances to private individuals who are not blocked are not prohibited by the Venezuela program. General License 16C covers U.S. persons’ accounts at Banco de Venezuela, Banco Bicentenario and Banco del Tesoro, and noncommercial personal remittances through those banks and the Central Bank; transfers to support a business, even a family business, are not personal remittances. Banks may still review such transfers — see frozen accounts and transfers with a Venezuelan link.
What happens if my company violates Venezuela sanctions?
A U.S. person faces civil penalties of up to $377,700 per violation or twice the transaction value, and criminal prosecution for willful violations. A non-U.S. company risks being designated itself and can face civil penalties for causing a U.S. bank or other U.S. person to violate the sanctions. A voluntary self-disclosure is a significant mitigating factor if a violation is discovered.
Can a Venezuelan person or company be removed from the SDN List?
Yes. Designated persons can ask OFAC to reconsider under 31 C.F.R. § 501.807, for example after a change in role, ownership or conduct. OFAC removed a number of Venezuela-related designations in 2026; each request is decided on its own record.
