What Changed After Maduro: Venezuela's New Regulatory Landscape for US Companies

This post is for informational purposes only and does not constitute legal advice. The Venezuela sanctions landscape is changing rapidly. Companies should consult qualified legal counsel before taking any action based on the information below.

On January 3, 2026, US forces captured Nicolás Maduro and transported him to New York to face narco-terrorism charges. For businesses that had been watching Venezuela from the sidelines for years, the news triggered immediate questions: Is Venezuela open now? Can we transact? Can we pay?

The short answer is: not yet fully, but the framework is moving fast and the window for early movers is opening.

Here is what the regulatory landscape actually looks like as of March 2026.

The Sanctions Did Not Go Away When Maduro Did

The most important thing for any compliance officer or general counsel to understand is this: despite the removal of Maduro from power, all Venezuela sanctions remain in place, including those prohibiting transactions and activities involving the Government of Venezuela (GoV), PdVSA, Minerven, and the oil and gas sector.

As of the time of writing, the US government has left in power the remaining leadership of the Maduro administration, including multiple Specially Designated Nationals (SDNs) with whom US persons are prohibited from dealing, absent OFAC authorization.

This matters because the temptation to move quickly is real and the risk of moving without proper authorization is significant. We believe companies should be aware that in similar past situations, the government has acted against persons who moved ahead of sanctions relief based on public statements that previewed but did not themselves effect the necessary regulatory changes. Companies should not treat political signals as legal authorization.

The Broad Scope of "Government of Venezuela"

One of the most misunderstood aspects of the Venezuela sanctions program is how broadly the Government of Venezuela is defined. Under Executive Order 13884, the GoV is broadly defined to include government agencies, the Central Bank of Venezuela, PdVSA, any entities owned or controlled directly or indirectly by the government, and anyone acting on behalf of the government.

This means US persons can be in violation even when transacting with a counterparty that does not appear on the OFAC SDN List, if that counterparty has ties to the GoV. While the blocking restrictions technically apply to US persons, non-US persons are also potentially exposed to secondary sanctions if they are found to have materially assisted or provided goods or services to designated entities. Additionally, transactions that clear in US dollars through the US financial system are subject to US jurisdiction, exposing non-US banks and entities to compliance risk.

What OFAC Has Actually Done Since January 2026

Since Maduro's capture, OFAC has moved to selectively ease restrictions, primarily focused on the energy sector. The pace of change has been significant.

On January 29, 2026, OFAC issued General License 46, authorizing certain transactions relating to the lifting, refinement, and trade of Venezuelan-origin oil by established US entities. This was the first formal OFAC action easing the general Venezuela sanctions regime following the capture.

GL 46 was replaced and superseded in its entirety by General License 46A on February 10, 2026.

During the first half of February 2026, OFAC issued a further series of new general licenses: GL 47 on February 3, GL 48 on February 10, and GL 49 and GL 50 on February 13, authorizing respectively the sale of US-origin diluents to Venezuela, the supply of goods and services for oil and gas exploration and development, the negotiation of contingent contracts for investments in Venezuela's oil and gas sector, and broadly all oil and gas sector transactions for certain specified oil companies and their subsidiaries.

As of early March 2026, OFAC issued General License 51 authorizing certain activities involving Venezuelan-origin gold.

The direction of travel is clear. The pace is fast. But each license comes with specific eligibility requirements, reporting obligations, and payment restrictions that companies must satisfy before relying on them.

Payment Restrictions Are Still Strict

Even under the new licenses, how payments can be made remains tightly controlled. Any monetary payment to a sanctioned person must be deposited into accounts of the US Department of the Treasury as described in Executive Order 14373, with the only exception being payments of local taxes, permits, or fees.

GL 48 expressly prohibits payment terms that are not commercially reasonable, or that involve debt swaps or payments in gold.

Transaction Reporting Is Now Required

The new licenses introduce active reporting obligations that did not exist under prior frameworks. Any person that exports, re-exports, sells, resells, or supplies Venezuelan-origin oil to countries other than the US pursuant to GL 46A must file a detailed report within ten days after the first such transaction, and every 90 days thereafter.

What This Means for Companies Evaluating Venezuela

The regulatory picture as of March 2026 is one of selective, fast-moving easing with significant compliance obligations still attached. For companies evaluating Venezuela re-entry, the practical takeaway is this: the question is no longer whether engagement is possible under certain conditions. The question is whether your payment infrastructure, compliance controls, and reporting systems are ready to support it.

Frequently Asked Questions

Are Venezuela sanctions still in effect after Maduro was captured?

Yes. The capture of Maduro on January 3, 2026 did not lift or suspend any Venezuela sanctions. All sanctions on the Government of Venezuela, PdVSA, Minerven, and the oil and gas sector remain in full effect.¹

What is a General License and do I need one to transact with Venezuela?

A General License is a standing authorization issued by OFAC that permits certain categories of transactions that would otherwise be prohibited. Since January 2026, OFAC has issued GL 46A, GL 47, GL 48, GL 49, GL 50A, and GL 51, each covering specific activities primarily in the oil, gas, and gold sectors.²

Who counts as the "Government of Venezuela" under US sanctions?

Under Executive Order 13884, the Government of Venezuela includes government agencies, the Central Bank of Venezuela, PdVSA, any entity owned or controlled directly or indirectly by the government, and anyone acting on behalf of the government.³

How do I make a payment to a Venezuelan counterparty under the new General Licenses?

If your counterparty is a private Venezuelan company with no ties to the Government of Venezuela or PdVSA, payments can generally be made through normal commercial channels, provided the underlying transaction is authorized. If your counterparty is a blocked person, any monetary payment must be deposited into Foreign Government Deposit Funds established under Executive Order 14373.⁴

Are there reporting requirements when transacting under the General Licenses?

Yes. Companies relying on GL 46A, GL 47, GL 48, and GL 50A must file detailed reports with the US Department of State and the US Department of Energy within ten days of the first transaction and every 90 days thereafter.⁵

Sources

¹ Morgan Lewis, Compliance Landscape in Venezuela Following Nicolás Maduro's Removal from Power, January 8, 2026.

² OFAC, Venezuela-Related Sanctions, updated March 2026.

³ Cleary Gottlieb, Navigating Venezuela Sanctions, January 16, 2026.

⁴ Mayer Brown, OFAC Issues New General Licenses Expanding Permitted Activities in the Venezuelan Energy Sector, February 2026.

⁵ Baker Botts, The E&P Playbook for Unlocking Venezuela, February 2026.

⁶ West of England P&I, Venezuelan Sanctions — OFAC Issues Various New General Licenses, February 2026.

⁷ OFAC, Frequently Asked Questions — Newly Added, March 4, 2026.

This post is for informational purposes only. It does not constitute legal advice. The Venezuela sanctions landscape is subject to rapid change. Companies should consult qualified legal counsel before entering into any transactions involving Venezuela or Venezuelan counterparties.