Venezuela Sanctions in Practice: 5 Things You Need to Know

Holland & Knight Partners Stephanie Connor and Andres Fernandez recently sat down to discuss the rapidly evolving Venezuela sanctions landscape, including the current authorizations, friction points, and how companies and financial institutions should position themselves. Here are the five key takeaways:

1. Sanctions Relief Is Expanding, But Read the Fine Print. Since January 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued multiple new or amended general licenses authorizing activities involving oil and gas, electricity, minerals (including gold) and financial services in Venezuela. Many of these licenses include strict limitations, conditions and reporting requirements. The framework provides a deliberate and surgical approach to sanctions relief – but the underlying architecture of U.S. sanctions remain in place.
2. Transactions Are Flowing, But Compliance Requirements Are Significant. Oil and gas deals are in the works, but financial institutions are scrutinizing transactions to make sure that they comply with OFAC's authorizations. Financial institutions can rely on customer representations as part of normal due diligence, but that reliance needs to be supported by a risk-based review of underlying materials.
3. Financial Institutions Are the Gatekeepers. Banks are the front line of sanctions enforcement, and U.S. government regulators know it. Federal banking regulators are actively asking institutions whether they have updated their risk assessments to account for Venezuela-related activity.
4. Exceptions Make the Rule. For the most part, OFAC's general licenses expressly exclude transactions involving entities owned or controlled by persons in China, Russia, Iran, North Korea and Cuba. Identifying those connections requires active due diligence. Moreover, the licenses do not authorize anything that would otherwise be prohibited by foreign terrorist organization (FTO) sanctions. With groups like Tren de Aragua and Cartel de los Soles designated as FTOs – and their deep ties to the Venezuelan government and mining sector well documented – FTO exposure is a serious risk in the current environment.
5. Have a Plan Before You Engage. Before entering into any Venezuela transaction – whether an oil deal, mining concession or services contract – companies should work through a structured compliance checklist: Who are your counterparties, and are they directly connected to the government of Venezuela or Petróleos de Venezuela S.A. (PDVSA)? What is the flow of funds, and where are payments going? Are there any connections to prohibited jurisdictions? Do you have the systems in place to comply with the reporting and recordkeeping requirements? And, unless your situation falls outside what the general licenses already cover, think carefully before approaching OFAC for a specific license: The licensing team is stretched thin, and existing general licenses have been crafted to address most activities that the U.S. government seeks to encourage.

To hear the full conversation, listen to Episode 2 of Holland & Knight's Market and Geopolitical Advisory Podcast. For questions about Venezuela sanctions compliance, contact Stephanie Connor or Andres Fernandez.