Weekly Sanctions Update: January 7, 2026

• Published date: 09 January 2026
• Law Firm: Steptoe LLP
• Author: Mr Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Alexandra Melia, Darryl Nirenberg, Wendy Wysong, Ali Burney, Quentin Johnson, Elliot Letts, Algirdas Semeta, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Zayna Dembinski, Wilson (Di) Zhao, Zoey Hong and Jonathan Eaton

The Sanctions Update is compiled by Steptoe's International Trade and Regulatory Compliance team and Steptoe's Strategic Risk team. You can subscribe to receive the Sanctions Update every week through Steptoe's International Compliance Blog and Stepwise Risk Outlook publication home pages.

For more information or advice on any of the developments discussed below, please contact a member of our sanctions team here.

US Developments

Maduro's Exit Could Reshape US Sanctions on Venezuela

On January 3, 2026, President Trump announced that the US had successfully carried out a large-scale military strike against Venezuela, resulting in the capture of Nicol's Maduro and his wife. During a press conference, President Trump stated that the US would "run" Venezuela until a "safe, proper, and judicious transition" occurs. Secretary of State Marco Rubio has stated that the US will enforce existing sanctions and an "oil quarantine" against Venezuela rather than playing a day-to-day role in governing the country.

Maduro's exit, coupled with US involvement in the transition, may have a significant impact on US sanctions policy in the region in the short and long terms.

Impact on Oil Sanctions

President Trump has stated that US oil companies will fix Venezuela's "broken infrastructure" and "start making money for the country." This will likely require, at a minimum, the issuance of licenses or other waivers allowing US oil companies to operate in the country without violating existing sanctions.

Restructuring of Sanctions

Likewise, as the transition unfolds, OFAC may also choose to restructure its Venezuela-related sanctions program. The Trump administration's reform of the Syria-related sanctions program in the aftermath of the Bashar al-Assad regime could potentially serve as a model for similar changes to Venezuelan sanctions. For example, OFAC could remove some of the existing sanctions, but maintain designations against individuals and entities associated with Maduro or Venezuelan cartels or transnational criminal organizations (TCOs).

Near Term Sanctions Measures

Finally, it is also possible that OFAC ramps up sanctions pressure in the short-term to facilitate the transition or hinder the operations of Maduro's supporters, cartels in Venezuela, or other malign actors. Just before the military strike, OFAC issued two separate rounds of sanctions against such actors on December 19 and December 31, 2025.

It is too early to predict the scope and timing of potential changes in US sanctions. Whether and how such changes unfold will largely depend on how the transition unfolds and the priorities of the Trump administration.

US Repeals Caesar Act

On December 18, 2025, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2026 (the "FY26 NDAA") (S. 1071). Among other measures, the FY26 NDAA included a full repeal of the Caesar Syria Civilian Protection Act of 2019 (the "Caesar Act"), removing the threat of mandatory Caesar Act sanctions for foreign persons providing support to the Government of Syria and engaging in certain transactions involving Syrian industry, including the infrastructure and energy sectors.

Shortly after the bill was signed, the Departments of the Treasury, Commerce, and State updated their Tri-Seal Advisory, clarifying the sanctions and export controls relief provided to Syria in the aftermath of the Bashar al-Assad regime. While most sanctions, with the exception of those on members of the al-Assad regime as well as other human rights abusers, Captagon traffickers, and other destabilizing actors, have been lifted, the Department of State is still...