Recent Developments in Venezuela-Related Sanctions

The U.S. Office of Foreign Assets Control (OFAC) continues to enforce its Venezuela-Related Sanctions program under 31 CFR Part 591, targeting the Venezuelan government, designated individuals and entities, as well as those operating in sectors majority-owned (50% or more) by the government.  The sanctions landscape continues to become more restrictive, particularly affecting the petroleum sector and associated logistical services.

In March 2025, a new restriction was introduced via Executive Order 14245, which authorises a 25% tariff on goods brought into the United States from any country that imports Venezuelan oil, whether directly or indirectly. OFAC is also revoking certain previously-issued general licences relating to the oil and gas sector in Venezuela. This includes licences that had enabled foreign and U.S. firms to conduct limited operations with the state oil company, Petróleos de Venezuela, S.A. (“PdVSA”).

Given these developments, transactions involving vessels that load crude or products from PdVSA or its subsidiaries, or that are otherwise engage in oil-sector operations, should be approached with heightened caution. The imposition of the tariff measure also expands the risk profile to third-party countries: any nation importing Venezuelan oil may face U.S. tariffs on its goods entering the American market.

Canada, the EU and the UK maintain similar sanctions enforcing restrictive measures on individuals, assets and travel.  The European Union extended its sanctions by one year (until 10 January 2026) and broadened listing criteria to include additional senior government officials.  On 21 March 2025, Canada added eight Venezuelan officials as designated parties, bringing Canada’s total number of sanctioned individuals to 139.  Consequently, all entities must carefully assess their exposure when engaging in transactions involving Venezuelan-origin oil or related services.

The Club continues to closely monitor these sanctions and will provide timely updates as material developments arise.

The above is for general, informational purposes only and does not constitute legal advice. Members requiring further information should reach out to their usual contact at the Club. Specific legal advice should be sought by Members to clarify how the sanctions may impact their business.