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Articles + Publications January 9, 2026
On January 7, the U.S. Department of Energy (DOE) announced a significant shift in the U.S. government’s approach to Venezuela’s oil sector, pairing targeted sanctions relief with a U.S.-directed framework for the marketing and sale of Venezuelan crude oil and petroleum products. This announcement follows the January 3 apprehension of Nicolás Maduro by U.S. authorities. See our previous advisory for a summary of these earlier developments from a sanctions perspective. No public changes to U.S. sanctions or export control regulations have yet occurred. However, the U.S. government is likely open to issuing specific licenses in select cases, and may be considering targeted public regulatory changes as well, such as the issuance of general licenses, in order to support this new policy announced by DOE. Collectively, the announced measures are framed as advancing U.S. national security interests, restoring Venezuelan oil production capacity, and ensuring that oil revenues are distributed under U.S. oversight.
Key Elements of the US-Venezuela Energy Framework
According to DOE’s January 7 fact sheet, the new framework includes the following components:
Sanctions Status and Legal Reality
Despite DOE’s public statement regarding an intention to implement selective sanctions relief, the Venezuela sanctions regime remains intact, as no changes to the legal framework have yet been implemented by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).
Key points for compliance purposes include:
Except when operating pursuant to OFAC authorization and any other required authorization (e.g., under U.S. export controls), Venezuela-related oil, shipping, financing, and other transactions should continue to be treated as high risk.
What This Means for the Energy and Financial Services Industries
Energy Producers, Traders, and Refiners
For refiners — particularly U.S. Gulf Coast facilities configured for heavy crude — the framework signals the possible reintroduction of higher volumes of Venezuelan barrels into lawful supply chains. However, participation is expected to be tightly controlled and routed through U.S.-approved mechanisms. Companies should not assume broader market access absent explicit authorization.
Oilfield Services, Equipment, and Infrastructure Providers
The authorization of select equipment, services, and grid-related support creates potential opportunities, but these are likely to be accompanied by licensing conditions, end-use restrictions, and ongoing monitoring. Activity is expected to focus on stabilization and incremental production gains.
Commodity Trading, Shipping, and Logistics
Shipping companies, traders, and logistics providers remain exposed to sanctions risk if they engage outside approved channels. Enhanced diligence remains critical for vessel ownership, chartering arrangements, port calls, and cargo financing, particularly where Venezuelan-origin crude is involved.
Overall Industry Takeaway
The administration’s actions reflect a controlled reopening of Venezuelan oil markets rather than a broad normalization. Commercial opportunities will depend on formal OFAC implementation, not policy statements alone. Until actual regulatory change and/or guidance is issued, companies should proceed cautiously, ensure that any engagement is expressly authorized where required, and maintain enhanced compliance controls.
Looking Ahead
Market participants should closely monitor OFAC releases for new general licenses, FAQs, or regulatory amendments addressing Venezuelan oil, shipping, financing, and services. We expect further clarification to determine which market participants may engage, under what conditions, and with what compliance obligations. Still, for some companies, now is the time to begin the process of applying for specific authorization where required. We will continue to track developments and are available to advise on licensing strategies and sanctions risk assessments related to Venezuela.
Sponsored Events
2026 AUTM Annual Meeting
February 8 – 11, 2026
Seattle, WA
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Leading the energy evolution.
Learn more
From compliance to the courtroom, we have you covered.
Learn more
Helping you focus on what matters – improving human health.
Learn more
Trusted advisors to leading insurers for 100+ years.
Learn more
Unlocking value in the middle market and beyond.
Learn more
Full-service legal advice from coast to coast.
Learn more
Applying radical applications of common sense
Explore More
Our standard-setting client experience program.
Explore more
Delivering life-changing help to those most in need.
Explore More
Our firm’s greatest asset is our people.
Explore More
Market-leading eDiscovery and data management services.
Explore more
The Pepper Center for Public Services
Explore more
Strategies helps businesses and individuals solve the complexities of dealing with the government at every level. Our team of specialists concentrate exclusively on government affairs, representing clients nationwide who need assistance with public policy, advocacy, and government relations strategies.
This unique program provides innovative and affordable opportunities to startups and early-stage emerging companies with a solid technology or scientific foundation. We help companies that have a quality management team in place and do not have other significant legal representation.
eMerge’s lawyers and technologists work together to deliver strategic end-to-end eDiscovery and data management solutions for litigation, investigations, due diligence, and compliance matters. We help clients discover the information necessary to resolve disputes, respond to investigations, conduct due diligence, and comply with legal requirements.
Stay ahead of the curve and in touch with our latest thinking on the issues that are top of mind across our practices and industry sectors.
Change happens fast in today’s turbulent world. Stay on top of the latest with our industry-specific channels.
Take a closer look at how we partner with clients to help them realize their goals.