Washington combines family sanctions, regulatory adjustments, and specific licenses to control the financial flow of the Venezuelan regime and the future of its oil assets.
On December 19, the U.S. Department of the Treasury took a new step in its strategy to pressure Nicolás Maduro’s regime by sanctioning relatives and close associates of the Maduro-Flores clan, updating the list of blocked individuals by the Office of Foreign Assets Control (OFAC), and issuing a new General License related to PDVSA. This move signifies a clear tightening of the sanction policy while also maintaining a structured approach.
The latest measure includes General License 5T, which authorizes certain transactions related to the PDVSA 2020 bond with an 8.5% coupon, starting February 3, 2026. This license comes amid prolonged litigation, disputes among creditors, and the judicial process surrounding CITGO, Venezuela’s most valuable external asset.
Sanctions: Impact on Family Ties
Simultaneously, OFAC expanded its list of Specially Designated Nationals (SDN) to include immediate family members of Carlos Erik Malpica Flores, nephew of first lady Cilia Flores, as well as relatives of Panamanian businessman Ramón Carretero Napolitano, who is noted for his extensive financial ties with the regime.
Washington argues that these family networks are not passive actors but rather functional structures for corruption, asset concealment, and evasion of sanctions. This justifies the decision to block assets, prohibit transactions, and alert third parties—including international banks—about the risk of secondary sanctions.
General License 5T and the PDVSA 2020 Bond
General License 5T replaces and updates the previous framework applicable to the PDVSA 2020 bond, one of the most sensitive financial instruments in Venezuela’s oil sector. The limited authorization for transactions, conditional on specific dates, confirms that the United States maintains surgical control over legal flows associated with PDVSA, without lifting structural sanctions against the regime.
Analysts interpret this move as a way to organize the legal landscape in anticipation of future judicial decisions, without providing financial oxygen to Maduro’s regime.
The Productive Participation Contracts are Maduro’s mechanisms to evade sanctions and finance himself, despite being unconstitutional.
Key OFAC Licenses Related to PDVSA
Since 2019, OFAC has developed a fragmented licensing system for PDVSA, aimed at preventing the total collapse of the regional energy market, protecting U.S. legal interests while isolating the regime:
Humanitarian general licenses, permitting limited transactions for food, medicines, and humanitarian aid, without direct benefits to the state’s apparatus.
Specific licenses for energy companies, such as Chevron, granted under strict supervisory conditions, without direct payments to Maduro’s government.
Licenses tied to debt and litigation, such as those related to the PDVSA 2020 bond, which seek to channel legal disputes without releasing assets to the regime.
Temporary and conditional authorizations, subject to periodic review and reversible in case of political changes or non-compliance.
This scheme confirms there isn’t a financial normalcy for PDVSA; rather, there’s a technical control aimed at limiting collateral damage while keeping political pressure intact.
A Dual Strategy
The combination of personal sanctions, technical licenses, and regulatory adjustments—including updates to FAQs—reflects a dual approach: suffocating the corruption networks of the Chavista power while preserving Washington’s ability to manage legal, energy, and financial risks.
The message is unmistakable. The United States is not only targeting officials but entire structures: surnames, family ties, intermediaries, and financial mechanisms. In the case of PDVSA, the policy remains one of containment, not rescue.