Can U.S. companies still operate in Venezuela?

Only under specific OFAC General Licenses or specific licenses. Chevron, for example, operates under GL 41 issued in November 2022, while most oil-sector activity by other firms remains prohibited.

Does OFAC still recognize Juan Guaidó's government?

The U.S. recognized Guaidó as interim president from 2019 until late 2022, when the opposition-led National Assembly dissolved the interim government. OFAC continues to treat the Maduro regime as sanctioned but engages the Unitary Platform on negotiations.

OFAC Venezuela Sanctions Overview

The Venezuela sanctions program is run by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and codified at 31 C.F.R. Part 591. It combines targeted designations of individuals and entities on the Specially Designated Nationals (SDN) List with broader sectoral measures restricting dealings with the Government of Venezuela, the state oil company Petróleos de Venezuela, S.A. (PdVSA), and the Central Bank of Venezuela.

The program developed through a series of executive orders:

E.O. 13692 (March 2015), issued by President Obama, declared a national emergency over human rights abuses and corruption in Venezuela and authorized individual designations.
E.O. 13808 (August 2017) restricted access to U.S. debt and equity markets for the Government of Venezuela and PdVSA.
E.O. 13827 (March 2018) prohibited transactions in the Petro digital currency.
E.O. 13835 (May 2018) barred purchases of Venezuelan public-sector debt and PdVSA receivables.
E.O. 13850 (November 2018) authorized sanctions on persons operating in the gold sector, later extended to oil, finance, and defense.
E.O. 13884 (August 2019) imposed a blocking sanction on all property of the Government of Venezuela in U.S. jurisdiction.

OFAC operationalizes the program through SDN designations of officials around Nicolás Maduro and through General Licenses (GLs) that authorize otherwise prohibited activity. GL 41 (October 2023) allowed Chevron to resume limited oil production; GL 44 (October 2023) temporarily authorized oil and gas transactions following the Barbados Agreement between the Maduro government and the opposition Unitary Platform, but was allowed to expire in April 2024 after Caracas barred opposition candidates.

The program is distinct from, but interacts with, Treasury sanctions on individuals under the Global Magnitsky framework and Department of State visa restrictions. Compliance obligations apply to all U.S. persons worldwide and to transactions touching the U.S. financial system.

Frequently asked questions

No. They are a hybrid program combining individual SDN designations with sectoral restrictions on the government, PdVSA, and the central bank, rather than a full embargo on commerce with the country.

The program developed through a series of executive orders:

E.O. 13692 (March 2015), issued by President Obama, declared a national emergency over human rights abuses and corruption in Venezuela and authorized individual designations.
E.O. 13808 (August 2017) restricted access to U.S. debt and equity markets for the Government of Venezuela and PdVSA.
E.O. 13827 (March 2018) prohibited transactions in the Petro digital currency.
E.O. 13835 (May 2018) barred purchases of Venezuelan public-sector debt and PdVSA receivables.
E.O. 13850 (November 2018) authorized sanctions on persons operating in the gold sector, later extended to oil, finance, and defense.
E.O. 13884 (August 2019) imposed a blocking sanction on all property of the Government of Venezuela in U.S. jurisdiction.

Frequently asked questions

No. They are a hybrid program combining individual SDN designations with sectoral restrictions on the government, PdVSA, and the central bank, rather than a full embargo on commerce with the country.

Frequently asked questions

Go deeper than the definition

Frequently asked questions

Go deeper than the definition