U.S. sanctions and Venezuela: key considerations

On January 3, 2026, the United States conducted an operation in Venezuela that resulted in the capture and extradition of Venezuelan President Nicolás Maduro and his wife, Cilia Flores. President Maduro’s arrest and removal from power raise fundamental questions about the future of US foreign policy toward Venezuela, including the implications for US sanctions targeting the country. The trajectory of the Venezuela sanctions program will likely depend on several factors that remain unknown – most notably, who will govern Venezuela and the level of cooperation the United States will receive from acting officials, many of whom are longstanding Maduro supporters. Even so, public statements from the Trump administration, including the President himself, signal a vision for Venezuela that would be difficult to pursue absent some degree of sanctions relief.

Current U.S. sanctions landscape

Over the past several years, sanctions have been the primary economic tool the United States has used to exert pressure on Venezuela. As of today, the United States continues to maintain significant, though not comprehensive, sanctions targeting Venezuela. These measures include blocking (asset-freezing) sanctions targeting:

  • (i) the state and government of Venezuela;
  • (ii) any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and the state-owned oil company Petróleos de Venezuela, S.A. (PdVSA);
  • (iii) any person owned or controlled, directly or indirectly, by the government of Venezuela; and
  • (iv) 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.

As a result, US sanctions have created major barriers for both U.S. and international companies seeking to operate in Venezuela, causing many to abandon operations or refuse to operate in the country altogether.

Immediate business implications and market-access demands

In the aftermath of President Maduro’s ouster, President Donald Trump has demanded that Venezuela provide market access to US companies, particularly oil companies.

Under current US sanctions, however, US companies investing or otherwise operating in Venezuela face challenges that present significant legal and compliance risk, especially in the petroleum sector. Consequently, either rolling back some of the existing sanctions targeting Venezuela or licensing activity that would otherwise be prohibited will likely be an important step in enabling US companies’ access to the Venezuelan market. Potential investors should also consider corporate structures that afford protections under bilateral and multilateral investment treaties.

Signals from the administration on the oil sector

Comments made by Secretary of State Marco Rubio in an interview with CBS’s “Face the Nation” suggest that sanctions targeting Venezuela’s oil sector will remain in place until the United States sees “changes that not just further the national interest of the United States […] but also that lead to a better future for the people of Venezuela.”

Secretary Rubio offered examples of the changes the United States expects from the Venezuelan government, including changing the way the oil industry is run, stopping alleged drug trafficking, and ending alleged “cozy[ing] up to Hizballah and Iran.”

It may therefore take time for the United States to assess the Venezuelan government’s efforts on these fronts before providing sanctions relief.

How sanctions could be adjusted

It is too early to predict whether, when, and how the Trump administration might change sanctions targeting Venezuela. We do know, however, that there are multiple avenues to calibrate the currently restrictive landscape. Unlike other US sanctions programs, the sanctions targeting Venezuela are almost entirely the product of executive action. Accordingly, if the Trump administration decides to make changes, it should be able to act with relative ease and expediency without needing to go through Congress.

It could begin by issuing broad general licenses, as it did as a first step toward rolling back sanctions on Sudan and Syria. Alternatively or in addition, President Trump could issue executive orders altering the scope of sanctions, particularly with respect to the government of Venezuela and/or PdVSA.

Outlook and ongoing guidance

The Trump administration’s plans for sanctions targeting Venezuela are not yet clear, but President Maduro’s removal from power has the potential to mark a turning point.

For the time being, however, sanctions remain a significant obstacle for companies currently operating in Venezuela, or seeking to operate there.

Disclaimer: this summary is provided for informational and educational purposes only and does not constitute legal advice. It is intended to offer a general overview of recent regulatory developments based on publicly available information. Readers should not act upon this information without seeking specific legal or compliance advice tailored to their particular circumstances. No attorney-client relationship is created by this summary, and the author assumes no responsibility or liability for any actions taken or not taken based on its contents. 

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