Venezuela Sanctions Compliance: Key Insights for Financial Institutions

In May 2026, Holland & Knight partners discussed the evolving landscape of U.S. sanctions on Venezuela, particularly following the issuance of new general licenses by the Office of Foreign Assets Control (OFAC) in January 2026. These licenses allow certain transactions in the oil, gas, electricity, and financial sectors, but compliance remains complex due to overlapping restrictions and ongoing Foreign Terrorist Organization (FTO) designations. Financial institutions must navigate these changes carefully, ensuring detailed documentation and updated risk assessments. The podcast highlights the importance of understanding what is authorized and the potential risks involved in engaging with Venezuelan entities. Companies are advised to stay informed about the regulatory environment and prepare for potential enforcement actions.

Key Points: • OFAC issued new general licenses for Venezuela's oil and gas sectors in January 2026. • Compliance failures can lead to significant penalties, despite authorized transactions. • Financial institutions must maintain detailed documentation and risk assessments.