Comprehensive guide to OFAC sanctions programs, the Specially Designated Nationals (SDN) list, and how they affect business with Venezuela.
OFAC administers and enforces US economic and trade sanctions against targeted foreign countries, regimes, terrorists, narcotics traffickers, and other threats to national security.
The Office of Foreign Assets Control (OFAC) is a division of the US Department of the Treasury. Established during the War of 1812 and formalized in its current form in 1950, OFAC is the primary agency responsible for administering and enforcing economic and trade sanctions based on US foreign policy and national security objectives.
OFAC maintains several sanctions lists, each serving a distinct purpose:
OFAC sanctions are based on authorities granted by the International Emergency Economic Powers Act (IEEPA), the Trading with the Enemy Act (TWEA), and specific country-based legislation. US persons—including all US citizens, permanent residents, entities organized under US law, and anyone physically located in the United States—must comply with OFAC regulations regardless of where a transaction occurs.
The Specially Designated Nationals and Blocked Persons (SDN) List is OFAC’s most consequential sanctions tool. Being placed on the SDN list effectively cuts an individual or entity off from the US financial system.
When OFAC designates a person or entity as a Specially Designated National, two primary consequences follow:
Under OFAC guidance, any entity that is 50% or more owned, directly or indirectly, by one or more SDNs is itself treated as blocked, even if the entity does not appear on the SDN list by name. This means compliance teams must look beyond the published list and investigate the ownership structure of counterparties.
OFAC designations typically originate from interagency referrals involving the Treasury Department, State Department, and intelligence community. The process generally involves:
Designated persons may petition OFAC for removal from the SDN list by demonstrating that the circumstances leading to designation no longer apply or that the designation was based on insufficient evidence. The process involves submitting a written petition to OFAC, which will review the request and may consult with other agencies. Delisting can also occur as part of broader diplomatic negotiations, as has happened in the Venezuela context following political transitions.
OFAC provides a free online search tool at sanctionssearch.ofac.treas.gov. Users can search by name, ID number, country, or program to identify whether a person or entity appears on the SDN list or other OFAC lists.
Use our purpose-built sanctions checker to search all Venezuela-related OFAC designations, with context on each entry and related general licenses.
Search Venezuela SDN →The US sanctions program targeting Venezuela is one of OFAC’s most complex, built through multiple Executive Orders and modified by dozens of General Licenses.
Five Executive Orders form the legal backbone of the Venezuela sanctions program. Each targets different aspects of the Venezuelan government and economy:
| Executive Order | Date | Scope |
|---|---|---|
| E.O. 13692 | Mar 2015 | Initial authority to sanction persons undermining democratic processes, involved in human rights abuses, corruption, or political repression in Venezuela |
| E.O. 13808 | Aug 2017 | Restricted dealings in new debt and equity of the Venezuelan government, PDVSA, and any entity owned or controlled by them |
| E.O. 13827 | Mar 2018 | Prohibited transactions involving the Venezuelan government’s issuance of digital currency (the “Petro” cryptocurrency) |
| E.O. 13835 | May 2018 | Prohibited the purchase of debt owed to the Venezuelan government, including invoices and accounts receivable |
| E.O. 13850 | Nov 2018 | Authorized blocking of persons operating in Venezuela’s gold sector; later amended by E.O. 13857 (Jan 2019) to clarify that PDVSA is subject to blocking |
| E.O. 13884 | Aug 2019 | Broadest authority: blocked all property and interests in property of the Government of Venezuela, with limited exceptions |
Following the political transition in Venezuela in January 2026, the sanctions landscape has shifted significantly. While the Executive Orders remain technically in effect, the Treasury Department has issued new and amended General Licenses to facilitate legitimate economic activity in support of the transitional government. The practical scope of sanctions enforcement is now focused on individuals and entities associated with the former Maduro government and its illicit financial networks.
General Licenses (GLs) authorize activities that would otherwise be prohibited under the Executive Orders. They do not require individual application—any US person meeting the GL’s conditions may rely on it. Key active GLs for Venezuela include:
Authorizes transactions related to the maintenance of operations and contracts of Citgo Petroleum Corporation and its subsidiaries. Citgo, a US-based subsidiary of PDVSA, is managed by an ad hoc board recognized by the transitional government.
Authorizes certain transactions involving bonds issued by the Government of Venezuela and PDVSA, including secondary-market trading of existing debt instruments. Does not authorize new lending to the Venezuelan government.
Authorizes transactions related to oil and gas operations in Venezuela involving specified companies. Originally issued as a six-month license, it has been renewed and amended to support the transition-era energy sector.
Authorizes new investment in Venezuela in certain sectors, issued in connection with the political transition. Subject to conditions including compliance with anti-corruption requirements and reporting obligations to OFAC.
Explore all active OFAC General Licenses for Venezuela with plain-English summaries, scope analysis, and expiration tracking.
View All General Licenses →Major Venezuelan government entities and state-owned enterprises that have been designated under the Venezuela sanctions program.
| Entity | Type | Primary EO | Status |
|---|---|---|---|
| PDVSA (Petróleos de Venezuela, S.A.) | State oil company | E.O. 13850 | Blocked; GL 50A applies |
| CVP (Corporación Venezolana del Petróleo) | PDVSA subsidiary | E.O. 13850 | Blocked (50% rule) |
| Bandes (Banco de Desarrollo Económico y Social) | State development bank | E.O. 13884 | Blocked |
| Conviasa | State airline | E.O. 13884 | Blocked |
| Banco Central de Venezuela | Central bank | E.O. 13884 | Blocked; under review |
| Minerven | State mining company | E.O. 13850 | Blocked (gold sector) |
| CANTV | State telecom | E.O. 13884 | Blocked (Gov’t of Venezuela) |
Step-by-step guide to searching OFAC’s official sanctions database and integrating screening into your compliance workflow.
For automated screening, OFAC provides the full SDN list in multiple machine-readable formats:
Comma-separated values suitable for spreadsheet analysis and database import. Available from the OFAC website.
Full structured data including all aliases, addresses, and identification documents. Preferred for automated compliance systems.
Human-readable list published periodically. Useful for reference but not recommended for automated screening.
Many financial institutions and businesses use commercial sanctions screening software that integrates OFAC data with other sanctions lists (EU, UN, UK, Canada). These tools typically offer fuzzy-name matching, real-time updates, and audit-trail features that exceed the capabilities of OFAC’s free tool. Major providers include Dow Jones Risk & Compliance, Refinitiv World-Check, and LexisNexis.
Our free screening tool covers all Venezuela-program SDN entries with enhanced context, related General Licenses, and entity relationship mapping.
Check Venezuela SDN List →A robust OFAC compliance program is essential for any organization conducting business with or involving Venezuela. OFAC has published detailed guidance on the elements of an effective compliance program.
Establish robust KYC procedures that include beneficial ownership identification. The 50% rule means you must determine not just who your direct counterparty is, but who ultimately owns and controls them. Enhanced due diligence is required for Venezuelan counterparties.
Screen all parties to a transaction—including intermediaries, beneficial owners, and end users—against the SDN list and other OFAC lists before processing. Re-screen existing relationships whenever OFAC updates its lists (typically multiple times per month).
Maintain records of all compliance screening, due diligence, and blocked or rejected transactions for at least five years. OFAC may request documentation during examinations. Records should include screening methodology, results, and any follow-up analysis.
If you discover an apparent OFAC violation, voluntary self-disclosure (VSD) to OFAC is a significant mitigating factor in enforcement proceedings. OFAC’s Economic Sanctions Enforcement Guidelines provide that VSD can reduce the base civil penalty by up to 50%.
The Venezuela sanctions program has undergone significant changes following the political transition in early 2026.
Common questions about the OFAC sanctions list, the SDN list, and Venezuela sanctions, answered in plain English.
The SDN List (Specially Designated Nationals and Blocked Persons List) is OFAC’s primary sanctions list, containing individuals and entities whose assets are fully blocked. The Consolidated Sanctions List is a single downloadable file that merges the SDN list with all other OFAC lists—including the Sectoral Sanctions Identifications (SSI) List, the Foreign Sanctions Evaders (FSE) List, and others. For comprehensive screening, compliance teams should use the Consolidated Sanctions List, as prohibitions may apply under non-SDN lists as well.
It depends on the nature of the business and the parties involved. Following the January 2026 political transition, OFAC has issued General Licenses authorizing certain categories of activity, including oil operations (GL 50A) and new investment (GL 52). However, broad sanctions under E.O. 13884 remain in effect, and any transaction involving SDN-listed parties or the former Maduro government apparatus remains prohibited. All Venezuela-related business activities should be reviewed by legal counsel experienced in US sanctions law before proceeding.
OFAC violations can result in severe penalties. Civil penalties can reach $330,000+ per violation or twice the value of the underlying transaction. Criminal penalties include fines up to $1,000,000 and imprisonment of up to 20 years per willful violation. OFAC enforces on a strict liability basis, meaning that even unintentional violations can result in penalties. Voluntary self-disclosure of violations is a significant mitigating factor. Companies and individuals may also face reputational harm, loss of banking relationships, and regulatory scrutiny.
OFAC updates the SDN list on a rolling basis, with changes published as they occur rather than on a fixed schedule. In practice, the list is typically updated multiple times per month, and sometimes multiple times per week. New designations, amendments, and removals are published in the Federal Register and on OFAC’s website. Compliance teams should subscribe to OFAC’s email notifications and re-screen counterparties whenever updates are published.
PDVSA and the Government of Venezuela remain on the SDN list. However, General License 46B authorizes certain secondary-market transactions involving existing Venezuelan sovereign and PDVSA-issued debt. This means holders can trade existing bonds on secondary markets, but new lending to or bond purchases directly from the Venezuelan government or PDVSA remain restricted unless specifically authorized. The status of bond sanctions may evolve as OFAC continues its post-transition review. Consult legal counsel before transacting in Venezuelan sovereign or PDVSA debt.
A General License is a standing authorization issued by OFAC that permits certain categories of transactions that would otherwise be prohibited under a sanctions program. Unlike a Specific License, which is granted on a case-by-case basis to a particular applicant, a General License is available to anyone who meets the stated conditions. General Licenses for the Venezuela program authorize activities such as oil operations (GL 50A), Citgo-related transactions (GL 5H), bond trading (GL 46B), and new investment (GL 52). Reliance on a General License should be documented in your compliance records.
Explore related tools and analysis on Caracas Research.
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Sources: US Department of the Treasury, Office of Foreign Assets Control; Federal Register notices; Executive Orders 13692, 13808, 13827, 13835, 13850, 13884; OFAC General Licenses; OFAC Sanctions List Search (sanctionssearch.ofac.treas.gov). All referenced regulatory documents are part of the public record.
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