Sanctions Update: January 7, 2026

• Published date: 09 January 2026
• Law Firm: Steptoe LLP
• Author: Steptoe LLP

The Sanctions Update, compiled by attorneys from Steptoe's award-winning International Regulatory Compliance team and the Stepwise: Risk Outlook editorial team, publishes every Monday. Guided by the knowledge of Steptoe's industry-leading International Trade and Regulatory Compliance team, the Sanctions Update compiles and contextualizes weekly developments in international regulatory enforcement and compliance, as well as offers insights on geopolitical context, business impacts, and forthcoming risks.

Subscribe to the Stepwise Risk Outlook here. To receive only the Sanctions Update edition (published most Mondays), select "Stepwise Risk Outlook: Sanctions Update." For more detailed analysis on related issues, see Steptoe's International Compliance Blog. For information on industry-specific monitoring or bespoke services, please contact the team here.

The Lede

What's Next for US Sanctions in Venezuela Post-Maduro

Last week, the US sanctions and military pressure campaign against Nicolas Maduro's regime in Venezuela culminated in a shock strike on Caracas and the extraction of Maduro and his wife to the US, where they will stand trial for conspiracy to import cocaine and related charges. The escalation follows months of heightened sanctions and growing military confrontation, ushering in a new era of US engagement with the country. The US has not yet commented on a new sanctions strategy for Venezuela beyond promising to enforce existing restrictions.

A few days before Maduro's extraction, the US issued sanctions on four companies and associated oil tankers it said were tied to Venezuela, a further move to deny the Maduro regime profits from its already heavily sanctioned oil trade. The sanctions followed the Trump administration's imposition of a blockade on all sanctioned oil tankers entering or departing Venezuela, and the seizure of sanctioned vessels amid heightened US military presence in the region. The narco-related sanctions regime has also increased in intensity: late last year, the US sanctioned entities, including the Cartel de los Soles (a group allegedly comprising Venezuela's top brass, all accused of participating in drug trafficking), as well as high-ranking individuals within the regime accused of facilitating the cocaine trade.

Secretary of State Marco Rubio has stated that the US will enforce existing sanctions and an "oil quarantine" on the country rather than playing a day-to-day role in governing the country or seeking new concessions from Caracas, such as oil access. This strategy officially represents a continuation of existing US policy in Venezuela'using sanctions pressure to compel policy changes, albeit now with much more leverage. It also diverges from President Trump's statements that the US is "in charge" and will "run" Venezuela post-Maduro's ouster, and will seek goals including a more US-friendly government, and reclamation of what Trump has described as "stolen" US oil.

The US' path to open up Venezuela's oil sector is obstructed: the interim leader, Maduro's vice president Delcy Rodriguez, is a regime insider who has condemned the US intervention (although she has since softened her stance, potentially in response to US pressure). Nonetheless, the Trump administration is betting on her to cut a deal in the short term, calling Rodriguez a "partner" and avoiding voicing support for opposition leader María Corina Machado, currently in exile since accepting the Nobel Peace Prize in Oslo late last year, but who has publicly floated returning to Venezuela and running for office again. Trump suggested that Machado would not have the support from key power brokers, like the military, to run the country, and signaled that the US intends to work with Rodriguez until a managed political transition can take place.

Despite Acting President Rodriguez's reluctance, the US' current plan appears to be applying pressure'via the threat of sanctions and military action'against the current interim government to make desired policy changes in Caracas. The plan largely focuses on opening the country's oil sector to American investment, forming a transitional government, and shifting the country's economy to an open market.

The recovery of the Venezuelan economy and, particularly, its hobbled oil...