A More Functional Opening, Not a Fundamental Shift
U.S. sanctions on Venezuela continue to evolve in measured steps. Since our last alert, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued a new set of general licenses and related guidance that further refine how U.S. companies may engage with the Venezuelan market. These actions build on OFAC’s earlier recalibration by authorizing broader use of contingent contracting with the Government of Venezuela and opening limited financial services channels involving key Venezuelan banks, while keeping the core restrictions firmly in place.
For companies considering opportunities in Venezuela, these developments create additional room to act — but not a clear path to full operations. OFAC’s recent measures continue to emphasize that progress will occur in stages. What matters now is not just what activity is allowed, but how companies structure transactions, select counterparties, and handle payments.
