Client Alert: Treasury Expands Venezuela-Related Sanctions Through New Designations and Licensing Actions
On December 19, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a further expansion of Venezuela-related sanctions, taking coordinated action that included new Specially Designated Nationals (“SDN”) designations, the issuance of a Venezuela-related general license, and updated compliance guidance. These measures reflect the Trump Administration’s continued focus on applying targeted financial pressure against individuals and networks linked to narco-corruption and state-controlled energy activity in Venezuela. [1]
OFAC designated seven individuals under Executive Order 13850 and related authorities for their alleged involvement in corruption and financial activity connected to Venezuela’s state oil sector. Treasury described the action as targeting individuals tied to the inner financial and familial networks supporting President Nicolás Maduro’s government, including activity linked to Petróleos de Venezuela, S.A. (“PdVSA”) and related commercial arrangements. [2] As a result of these designations, all property and interests in property of the listed individuals that are subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions or dealings with them absent specific authorization.
These actions form part of a broader U.S. strategy aimed at isolating revenue streams supporting the Maduro government, particularly in the energy sector. Treasury’s latest measures target individuals described as benefiting from corruption and misuse of Venezuela’s oil wealth, while reinforcing that sanctions relief remains limited and conditional.
In parallel with the designations, OFAC issued Venezuela-related General License 5T, addressing transactions involving PdVSA 2020 8.5% bonds. General License 5T was the latest in a series of general licenses preserving the future ability of PdVSA bondholders to enforce their rights but delays the effective date (as did the prior general licenses) pending some restructuring of PdVSA debt and resolution of CITGO ownership (which is currently in litigation in U.S. federal courts). The license authorizes limited activity relating to those instruments on or after February 3, 2026, subject to strict conditions and ongoing sanctions restrictions. Treasury emphasized that the authorization is narrow and does not broadly relax Venezuela-related sanctions or permit new investment activity involving sanctioned Venezuelan state entities. ([3]
OFAC also published an amended Venezuela-related Frequently Asked Question, clarifying aspects of compliance under the Venezuela sanctions regime. The updated guidance underscores Treasury’s continued focus on indirect dealings, beneficial ownership, and attempts to evade sanctions through family members, intermediaries, or complex ownership structures tied to the Venezuelan oil sector.[4] The FAQ notes the CITGO litigation and ongoing efforts to restructure payments to PdVSA 2020 8.5 percent bondholders, stating that additional licensing requirements may apply and that “OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.”
From a compliance perspective, the December 19 actions reinforce several key themes. First, OFAC continues to prioritize individual and network-based designations, increasing exposure for counterparties connected—directly or indirectly—to sanctioned Venezuelan officials. Second, the issuance of a narrowly tailored general license underscores that most Venezuela-related transactions remain prohibited, and reliance on licensing requires careful, fact-specific analysis. Third, non-U.S. persons remain exposed to secondary sanctions risk where they knowingly facilitate significant transactions involving designated persons or blocked property.
In sum, OFAC’s December 19 actions demonstrate sustained U.S. enforcement momentum against Venezuelan corruption and energy-sector activity. Companies operating in or adjacent to Venezuelan markets—including financial institutions, energy traders, insurers, and shipping companies—should remain vigilant in their sanctions compliance programs, counterparty due diligence, and exposure to Venezuela-related risk in light of these developments.
[1] U.S. Department of the Treasury, Office of Foreign Assets Control, Recent Actions, https://ofac.treasury.gov/recent-actions/20251219 (Dec. 19, 2025).
[2] U.S. Department of the Treasury, Treasury Targets Family Members and Associates of Maduro Regime, https://home.treasury.gov/news/press-releases/sb0343 (Press Release, Dec. 19, 2025).
[3] OFAC, Venezuela-related General License 5T, https://ofac.treasury.gov/media/934866/download?inline (Dec. 19, 2025).
[4] OFAC, Venezuela Sanctions FAQs, https://ofac.treasury.gov/faqs/595 (updated Dec. 19, 2025).