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We hope everyone had a great holiday. 2026 is now officially off and running, and particularly in light of recent events, we want to briefly summarize current trade restrictions related to Venezuela. The landscape will almost certainly shift soon – and often – and we will provide updates as often as possible. Importantly, at present, there continue to be significant restrictions when doing business in and with Venezuela.
Economic Sanctions Target the Government and Designated Parties
U.S. sanctions on Venezuela are built on a series of executive orders. Initially focused on addressing human rights violations and corruption, these measures have expanded over time to encompass broader financial- and government-related restrictions.
As a result, U.S. sanctions on Venezuela are primarily list-based (i.e., parties on, or owned 50% or more by parties on, the List of Specially Designated Nationals and Blocked Persons (the SDN List) maintained by the U.S. Treasury Department, Office of Foreign Assets Control (OFAC)). Recent enforcement shows that the oil sector remains a key focus. For example, on December 31, 2025, OFAC sanctioned four companies for operating in Venezuela's oil sector and identified associated tankers as blocked property, characterizing them as part of a sanctions-evasion "shadow fleet."
There are also broad restrictions when dealing with the "Government of Venezuela." Importantly, this risk is not limited to obvious state-owned enterprises: government-controlled banks, public-sector procurement, and certain public institutions create government touchpoints that must be scrutinized.
To be clear, Venezuela is not a comprehensively sanctioned country like Iran, and OFAC does maintain several general licenses to authorize transactions in and with the country, including those involving certain government actors. But it is also clear that Venezuela is not yet fully open for business.
U.S. Export Restrictions on Venezuela Target Defense and Sophisticated Dual-Use Products
Venezuela remains high risk from an export controls perspective, particularly where a transaction could implicate defense or sensitive dual-use controls.
Under the International Traffic in Arms Regulations (ITAR) administered by the U.S. Department of State, Venezuela is subject to a policy of denial for licenses and approvals involving exports or imports of defense articles and defense services.
Under the Export Administration Regulations (EAR) administered by the U.S. Department of Commerce, Venezuela is subject to specific military end use and end user restrictions. Since 2019, Venezuela has been listed as a country subject to heightened national security controls. Thus, an export license is still required to export many commercial items to Venezuela – even many items that generally can be exported to most countries around the world without a license.
Tariff, Import Risks Remain In Place
Like most other countries in the world, imports from Venezuela are subject to reciprocal tariffs – as of August 2025, the rate was 15%. Perhaps more notably, another 2025 executive order framework provides for a potential 25% tariff on goods imported into the U.S. from countries that import Venezuelan oil, directly or indirectly, subject to the determinations described in the order.
Summary – for now
If currently conducting or considering business involving Venezuela, significant restrictions continue to exist. While these will likely ease, many are also likely to remain in place, at least for the short term. The country is not open for business, and thus, for the foreseeable future, every Venezuela transaction needs to be reviewed on a case-by-case basis.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
