Executive Summary
The removal of Nicolás Maduro is a major enforcement milestone, but it has not resulted in regime change in Venezuela. Instead, power has transferred to figures closely tied to the existing system, and U.S. policy appears focused on controlling economic flows rather than effectuating governance change or normalizing relations. To date, U.S. actions signal selective, tightly managed engagement—particularly in the energy sector—while the broader sanctions framework remains firmly in place. At the same time, Venezuela continues to present systemic anti-money laundering (AML), corruption, and counterterrorism risk, which materially constrains both economic viability and banking access. Despite limited openings, the risk profile associated with commercial activity in Venezuela remains elevated, and early or inadequately structured engagements carry heightened enforcement and reputational exposure.
Key Takeaways: What You Need to Know and Do
- Do not assume broad sanctions relief. Authorizations are narrow, conditional, and reversible; recent enforcement actions and political developments do not signal normalization.
- Energy-related transactions are controlled, not open. Any oil-related engagement is subject to U.S. oversight of counterparties, settlement, and use of proceeds, and faces possible attachment or other litigation risk.
- AML and corruption risk remain extreme. Even sanctions-compliant activity may be commercially unworkable due to lack of counterparty clarity, pre-existing corruptions risk, and correspondent banking and diligence constraints.
- Counterparty risk is elevated. Informal political influence, indirect control, and legacy corruption ties—mixed with lack of governance clarity in Caracas—are difficult to detect and easy to miss.
- Focus on risk management and mitigation. There is a need to heighten sensitivity to sanctions, AML, counterterrorism, and Russia/China spillover risk. Expect retrospective scrutiny of decisions made during this transition.
What Happened: Hopes, Expectations, and Early Uncertainty
On 3 January 2026, Nicolás Maduro was removed from power and transferred to the United States to face federal charges. This was an extraordinary development amid rising tensions that immediately elevated expectations of political change and potential recalibration of U.S.–Venezuela relations.
In parallel, U.S. authorities unsealed a revised criminal indictment that sharpened long-standing allegations against Maduro personally. The indictment reinforced the basis for prior designations under U.S. counterterrorism authorities, citing Maduro’s role in enabling narcotics-linked networks that were characterized as Foreign Terrorist Organizations (FTOs). It portrayed Maduro not as a peripheral actor but rather as a political guarantor of a corruption-driven system that provided protection and institutional cover to traffickers and their facilitators. Rather than alleging direct operational control over a cartel-like organization, the updated charges emphasize his role in sustaining and shielding an informal, state-backed network of criminal activity.
While Maduro’s removal represents a significant enforcement milestone, it has not produced a clear political rupture. Authority has transitioned to his vice president, Delcy Rodriguez, thereby preserving the existing institutional framework, and questions remain about how governance structures and patronage relationships may evolve under new leadership.
The Trump administration has not articulated a comprehensive posture with respect to Venezuela’s political transition, long-term sanctions relief, or broader economic normalization. Actions to date instead reflect a limited and intentional effort to manage economic flows during the near-term leadership transition, particularly in the energy sector. U.S. authorities have authorized narrow, transaction-specific Venezuelan oil activity—subject to strict conditions governing counterparties, routing, and settlement.
Oil transactions are expected to be an early pressure point, with control over the settlement and disposition of proceeds at the center of near-term risk. The U.S. Department of Energy (DOE) is driving a deliberate commercial control strategy that permits limited activity while retaining gatekeeping authority over the end-to-end sale and proceeds of Venezuelan oil. Policy direction and transition mechanics remain unsettled, elevating risk for early movers and warranting heightened sensitivity to sanctions exposure, counterparty risk, and potential litigation.
Regional Reaction and Impact
The regional response has not been uniform. Some governments, especially those ideologically opposed to Maduro or aligned with U.S. policy goals, have publicly supported or welcomed the outcome (e.g., Argentina, Paraguay, Trinidad and Tobago). Others, particularly Brazil, Mexico, Colombia, and several Caribbean leaders, condemn the use of force and underscore concerns about sovereignty, regional stability, and international legal norms.
The trajectory for Venezuela’s political and diplomatic future may impact incentives for how Latin American countries strengthen or modify trade and investment ties with other trading blocs or key trading countries, signaling a broader geoeconomic reset in the region. Venezuela’s centrality to oil markets, shipping routes, and sanctions-evasion networks makes it a strategic chokepoint in the wider competition between the United States and its main rivals, particularly China and Russia. By disrupting their respective energy and financial links and reasserting leverage over Venezuelan oil flows, the U.S. government may be testing whether hard power, sanctions enforcement, and control over critical commodities can rebalance influence in the Western Hemisphere. At the same time, Latin America is economically far more integrated with China than in past decades, and coercive moves without credible trade, investment, and development incentives could alienate regional governments rather than realign them. Ultimately, the removal of Maduro from power in Venezuela can be seen as the most dramatic application of the “Trump Corollary” to the Monroe Doctrine—set in a longer, more uncertain economic and strategic contest with China.
Recent Developments and Early Signals
Recent engagements at the White House, including discussions with U.S. oil executives, provide early signals of U.S. intent. President Trump has indicated that U.S. oil companies are prepared to deploy significant private capital to rebuild Venezuela’s oil infrastructure, contingent on U.S. security and legal protections.[1]
- Investment was framed as coming from private capital, not government funding.
- S. involvement would center on protection, security, and legal certainty, not financing.
- Engagement in the Venezuelan economy appears to be conditional and controlled, rather than signaling broad sanctions relief.
- Settlement, access, and proceeds are expected to remain subject to U.S. oversight.
Strategic Context: For external stakeholders, the moment highlights a familiar dynamic:
- A high-profile action that suggests potential for change and opportunities for an economic opening.
- An uncertain trajectory as Venezuela enters a transitional phase whose contours and durability remain difficult to assess.
Early industry reactions underscore the conditional nature of potential engagement. Following the White House roundtable on 9 January, Exxon Mobil indicated interest in assessing Venezuela’s energy sector while also emphasizing that any future involvement would depend on legal reforms, investment protections, and contract sanctity. The response illustrates that, despite political developments, commercial decisions remain anchored in legal certainty rather than policy signaling alone.[2]
Executive Order Update: Safeguarding Venezuelan Oil Proceeds
On 9 January 2026, President Trump issued an Executive Order (EO) that materially clarifies the treatment, custody, and protection of Venezuelan oil proceeds. It declares a national emergency to prevent the attachment or garnishment of—or any other judicial processes against—Venezuelan oil revenues held in designated U.S. Treasury accounts. The order establishes that such funds constitute sovereign property of the Government of Venezuela, and may not otherwise be transferred, withdrawn, or otherwise dealt without prior authorization.
Importantly, it explicitly bars the use of these funds for commercial activity in the United States and protects the funds against private claims. The framework—modeled after the treatment of Iraqi oil proceeds in 2003—seeks to resolve near-term uncertainty regarding creditor attachment risk, while reinforcing U.S. control over timing, purpose, and disposition of Venezuelan oil proceeds.[3]
The Sanctions Reality: Historical Context and Current Posture
U.S. sanctions on Venezuela have evolved incrementally over nearly a decade, expanding significantly between 2017 and 2019 in response to democratic erosion, corruption, and human rights abuses. The sanctions regime has consistently been sector-specific and list-based—rather than comprehensive—targeting defined segments of the Venezuelan economy, the Venezuelan government and its debt and equity, and designated individuals and entities.
The program has targeted senior officials, government entities, and state-owned enterprises while preserving limited pathways for authorized engagement under general or specific licenses aligned with U.S. foreign policy objectives. In this respect, Venezuela’s sanctions framework has functioned more like the sanctions regime imposed on Russia than a comprehensive embargo: restrictive, highly conditional, and subject to rapid recalibration, but not an absolute prohibition on all commercial activity.
More recent actions by the U.S. Department of State in July and November 2025—designating certain Venezuelan-linked narcotics networks under Section 219 of the Immigration and Nationality Act (INA)—added a terrorism lens to the policy toolkit. This shift heightens legal exposure risks for investors and counterparties, including potential lawsuits by victims of terrorism under material support or aiding-and-abetting theories, given the expanded statutory reach of U.S. anti-terrorism laws.[4] The revised criminal indictment against Maduro reflects a more nuanced view of these networks as informal systems of protection and patronage rather than a centralized organization directed from the top.
Importantly, recent developments have not affected the underlying structure of the sanctions regime:
- Authorized activity remains limited, conditional, and highly dependent on U.S. strategic interests.
- Compliance risk continues to hinge on designation status, licensing scope, and enforcement posture rather than leadership changes alone.
Recent developments underscore that initial U.S. actions are focused on facilitating specific, authorized transactions rather than lifting sanctions at a systemic level.
This complexity makes Venezuela one of the most challenging jurisdictions to navigate. Firms should rigorously confirm licensing conditions and review designation lists and related sanctions risk before acting, as even minor missteps can trigger severe penalties or reputational risk exposure.
AML/CFT Risk: Persistent Vulnerabilities, and International Consensus
Independent of sanctions or political instability, Venezuela continues to present elevated and well-documented anti-money laundering and counter-financing of terrorism (AML/CFT) risk. The most comprehensive recent assessment—the March 2023 Mutual Evaluation conducted by the Caribbean Financial Action Task Force (CFATF) —identified deep structural deficiencies across Venezuela’s AML regime, including ineffective supervision, limited beneficial ownership transparency, weak enforcement outcomes, and pervasive exposure to corruption-driven predicate offenses.[5]
These findings were reinforced in October 2025, when the Financial Action Task Force plenary formally placed Venezuela under increased monitoring (grey listing), signaling sustained international concern regarding the country’s ability to address money laundering and terrorist financing risks. Thus far, no material remediation has been recognized, underscoring the persistence of structural deficiencies despite heightened scrutiny.
U.S. authorities have echoed these concerns for years:
- September 2017 (FIN-2017-A006): Highlighted widespread public corruption and misuse of state institutions.[6]
- May 2019 (FIN-2019-A002): Warned of heightened risks tied to state-owned enterprises, trade-based money laundering, and laundering of proceeds through international correspondent banking channels.[7]
Taken together, these assessments underscore a critical potential contradiction for regulated entities. The sanctions environment remains closely tied to U.S. strategic interests and may shift more permissively with policy changes. Venezuela’s underlying AML/CFT and corruption risk profile, however, has been consistently identified by U.S. and international standard setters as severe and systemic, and may grow more complicated without more fundamental governance changes.
This reality creates practical constraints. Achieving effective AML/CFT compliance is extremely challenging in a jurisdiction plagued by systemic corruption and opaque financial flows. As a result, even sanctions-compliant businesses may be unable to move funds in to or out of Venezuela due to restrictions imposed by banking partners.
Investor sentiment is expected to remain muted, as any engagement creates long-term exposure to an unstable regime. The country is burdened by sanctions, entrenched AML and anti-corruption risks, and a compliance environment unlikely to improve quickly, even if political dynamics shift.
These structural deficiencies make Venezuela one of the most challenging markets to justify from both a compliance and strategic perspective.
Potential Corruption Exposure, and Counterparty Due Diligence Considerations
In the current Venezuelan environment, politically exposed individuals and those with legacy ties to corrupt governance structures often influence commercial counterparties, even when those connections are not immediately visible. Corruption risk is especially acute in the extraction industry, energy trade, and other sectors where the government exercises near-absolute control. These vulnerabilities are likely to persist even where firms operate under tightly managed engagement or licensing frameworks.
Formal ownership disclosures and baseline screening often fail to capture informal influence, economic dependence, or decision-making authority exercised through intermediaries or affiliated parties. As enforcement expectations increase, regulatory scrutiny has expanded beyond direct relationships to include indirect ownership and control and influence. Yet conducting meaningful due diligence remotely can be nearly impossible, often failing to uncover real, on-the-ground risks tied to Venezuela’s well-documented corruption.
Operational Implications:
- Without localized intelligence and rigorous verification, firms face heightened exposure when committing capital, entering contracts, transferring funds, or allocating resources.
What’s Next: Uncertainty, Continuity, and Selective Engagement
While the removal of Maduro marks a significant inflection point, it cannot yet be characterized as regime change. Authority has simply shifted to figures closely associated with the same systems of corruption and repression that defined the prior government. This assessment aligns with Phase 1 of U.S. Secretary of State Marco Rubio’s three-phased approach—stabilization and conditional engagement—where the priority is preventing state collapse rather than endorsing an immediate political transition.[8]
From a sanctions perspective, current U.S. actions reflect limited, government-directed engagement focused narrowly on the energy sector, rather than broader commercial normalization. Activity to date has been driven by the U.S. government, principally through DOE, and structured to allow transactions only where the United States retains control over counterparties, transaction flows, and proceeds.
Under DOE’s framework, published on 7 January, the United States has selectively eased sanctions solely to enable the transport and sale of Venezuelan crude and oil products through U.S.-authorized channels.[9] This includes U.S.-directed crude marketing through designated commodity marketers and financial institutions, with proceeds settling into U.S.-controlled accounts prior to any distribution at the discretion of the U.S. government. DOE has indicated that initial sales are expected to begin immediately, with anticipated volumes of approximately 30–50 million barrels.
The framework also contemplates targeted authorizations for U.S. diluent exports, select oilfield equipment and services, and limited infrastructure rehabilitation, where necessary to stabilize production capacity. These measures are purpose-built and tightly scoped, preserving U.S. control over licensing, settlement, and access to proceeds.[10]
What these actions do not do: These actions do not constitute broad sanctions relief, do not reopen Venezuela to general commercial activity, and do not alter the underlying sanctions framework applicable to non-energy sectors or non-authorized counterparties.
Early indications point to a shift in trade dynamics:
- Rapid resumption of U.S.-bound oil exports just days after the operation.
- Complete halt of Chinese-bound shipments.
- Stepped-up maritime enforcement: U.S. authorities seized vessels before Maduro’s removal, signaling a more aggressive posture on maritime sanctions and commercial control.
- The seizure of ships evading sanctions has implications far beyond Venezuela. The seizures affect supplies to Cuba, China, and other Venezuelan partners and could signal a greater desire to use maritime seizures as a way of affecting Chinese, Russian, Iranian, and North Korean sanctions evasion and shadow fleets.
- Chinese financial regulators have begun reassessing risk matrices tied to Venezuela-linked relationships.[11]
DOE’s announcement further reinforces this approach by confirming that all proceeds from Venezuelan oil sales will settle in U.S.-controlled accounts at globally recognized banks.[12] Together with the Executive Order published on 9 January, these measures establish a U.S. gatekeeping role over the custody, use, and disposition of Venezuelan oil revenues. This structure mirrors earlier U.S. practice, including the treatment of Iraqi oil proceeds under EO 13303, and underscores that licensing and fund-access mechanics will remain central to risk and compliance considerations.
What comes next remains uncertain, but current signals suggest the United States will continue operating within the stabilization and conditional frameworks outlined in the U.S. Secretary of State’s phased strategy. In this fluid environment, regulatory guidance and enforcement priorities may evolve unevenly across agencies. Firms should not rely on policy statements alone when making risk-related decisions and should instead ensure that any engagement is grounded in clear, formal authorizations and confirmed regulatory requirements.
Overall risk has increased in recent weeks despite selective easing of sanctions restrictions, particularly in the energy sector. Underlying vulnerabilities—including corruption, AML/CFT deficiencies, and enforcement unpredictability over time—remain unchanged. Firms must continue to account for rising risk across multiple dimensions, even if certain commercial and payment channels reopen.
For firms considering new engagement with the Venezuelan economy: Decision making should assume shifting enforcement risk across multiple jurisdictions and over time. This includes potential enforcement by U.S. authorities for violations of license scope or settlement controls, the possibility of increased scrutiny by non-U.S. regulators, and changes in enforcement posture resulting from evolving U.S. policy or future administration priorities. Firms, therefore, should maintain heightened sensitivity to direct and indirect sanctions exposure, counterparty risk, and terrorism-related liability, particularly where decisions may be subject to retrospective review.
Contact our K2 Integrity sanctions experts to learn how we can support your compliance and risk management efforts.
[1] PBS NewsHour. “Trump Is Meeting With Oil Executives to Seek Investments in Venezuela.” 9 January 2026. Available at: https://www.pbs.org/newshour/politics/trump-is-meeting-with-oil-executives-to-seek-investments-in-venezuela.
[2] Reuters. “Exxon Mobil Still Interested in Venezuela Visit Despite Trump Rebuke.” 13 January 2026. Available at: https://www.reuters.com/business/energy/exxon-mobil-still-interested-venezuela-visit-despite-trump-rebuke-2026-01-13/.
[3] See Executive Order 13303, “Protecting the Development Fund for Iraq and Certain Other Property in Which Iraq Has an Interest.” Federal Register. Available at: https://www.govinfo.gov/content/pkg/WCPD-2003-05-26/pdf/WCPD-2003-05-26-Pg646.pdf.
[4] See 18 U.S.C. § 2339B Congressional Research Service. CRS Report on Terrorism Material Support Statutes. Available at: https://www.congress.gov/crs-product/R41333.
[5] Caribbean Financial Action Task Force (CFATF). Mutual Evaluation Report of the Bolivarian Republic of Venezuela. Available at: https://11edf.cfatf-gafic.org/ova_doc/mutual-evaluation-report-of-the-bolivarian-republic-of-venezuela/.
[6] Financial Crimes Enforcement Network (FinCEN). Advisory to Financial Institutions on Widespread Public Corruption in Venezuela (FIN-2017-A006). Issued 20 September 2017. Available at: https://www.fincen.gov/system/files/advisory/2017-09-20/FinCEN%20Advisory%20FIN-2017-A006-508%20Compliant.pdf.
[7] Financial Crimes Enforcement Network (FinCEN). Updated Advisory on Widespread Public Corruption in Venezuela (FIN-2019-A002). Issued 3 May 2019. Available at: https://www.fincen.gov/system/files/advisory/2019-05-08/Venezuela%20Advisory%20FINAL%20508.pdf.
[8] Secretary of State Marco Rubio has publicly described a three-phase framework for Venezuela focused on stabilization, recovery, and eventual political transition. Public statements indicate that the initial phase prioritizes preventing state collapse and maintaining control over key economic levers, including oil exports, while subsequent phases remain contingent and without a defined timeline. Miami Herald. “U.S. Prepares to Take Control of Venezuelan Oil Under Three-Phase Strategy, Rubio Says.” January 7, 2026. Available at: https://www.miamiherald.com/news/nation-world/world/americas/venezuela/article314237431.html.
[9] U.S. Department of Energy. Fact Sheet: President Trump Restoring Prosperity, Safety, and Security to the United States and Venezuela. 6 January 2026. Available at: https://www.energy.gov/articles/fact-sheet-president-trump-restoring-prosperity-safety-and-security-united-states-and.
[10] U.S. News and World Report. “Venezuela’s Oil Deliveries to Asia at Standstill, Chevron’s Exports Flowing – Shipping Data.” 6 January 2026. Available at: https://money.usnews.com/investing/news/articles/2026-01-06/venezuelas-oil-deliveries-to-asia-at-standstill-chevrons-exports-flowing-shipping-data.
[11] Windward. Maritime Defense Weekly – Week of January 5. Available at: https://windward.ai/blog/maritime-defense-weekly-week-of-january-5/.
[12] Public reporting indicates that at least some Venezuelan oil sales proceeds from initial U.S.-authorized transactions are being held in an account in Qatar, which has been described as a neutral location where funds can move under U.S. oversight without risk of seizure by creditors or courts. Details regarding the identity of the bank, the operational structure of the account, and how it will function (including whether proceeds will transfer to U.S. banks or how they will be accessed for client disbursement) have not been publicly disclosed.