The international sanctions regime targeting Venezuela represents one of the most expansive and coordinated efforts ever directed at a single nation outside the framework of the United Nations Security Council. The principal jurisdictions imposing these measures—the United States, the European Union, Canada, and several other nations—have constructed what amounts to a financial and economic cordon, with the United States maintaining the most elaborate and restrictive apparatus. These sanctions have evolved considerably since their initial imposition in 2005, escalating dramatically following the contested presidential elections of July, 2024.
The American Architecture
The United States maintains the most comprehensive sanctions system against Venezuela—a structure that began as targeted individual sanctions in 2015 and has metastasized into sweeping sectoral restrictions affecting the country’s economic arteries.
Individual Designations
As of November, 2025, the United States maintains sanctions against two hundred and nine individuals connected to Venezuela’s political and security apparatus. The initial sanctions, introduced in 2015, targeted government officials responsible for human-rights violations and repression. The list gradually expanded to include military personnel, judicial officials, members of the National Electoral Council (known by its Spanish acronym, C.N.E.), and intelligence officers. The most recent waves of designations, in January, 2025, swept up eight individuals associated with P.D.V.S.A.—the state oil company—and security forces, while the July, 2025, sanctions extended to members of the Tren de Aragua criminal organization.
Sectoral Measures
The United States has imposed broad sectoral sanctions aimed at Venezuela’s key revenue-generating sectors:
The Oil Sector—Executive Order 13857, issued in January, 2019, designated P.D.V.S.A. as a Specially Designated National (S.D.N.), freezing approximately seven billion dollars in assets and prohibiting U.S. persons from conducting transactions with P.D.V.S.A. and its subsidiaries. These sanctions initially prevented American companies from importing Venezuelan oil while simultaneously blocking P.D.V.S.A.’s ability to receive payments for oil exports to the United States.
The Gold-Mining Sector—The gold sector has been constrained through sanctions against the state-owned mining company Minerven since March, 2019, designed to limit the regime’s access to alternative revenue streams.
The Financial System—Sanctions target the Central Bank of Venezuela and other financial institutions, restricting access to American financial markets and limiting the capacity to conduct international transactions.
Digital Currency—Executive Order 13827 prohibits transactions involving digital currency issued by the Venezuelan government.
Debt Purchases—Executive Order 13835 prevents transactions related to the acquisition of Venezuelan debt.
Genesis of American Sanctions
Since 2005, the United States has imposed sanctions on Venezuelan individuals and entities engaged in criminal, anti-democratic, or corrupt activities. The U.S. Treasury Department has sanctioned at least twenty-two individuals and twenty-seven companies associated with Venezuela, designating them as Specially Designated Narcotics Traffickers under the Foreign Narcotics Kingpin Designation Act.
In response to escalating repression in Venezuela, Congress passed the Venezuela Defense of Human Rights and Civil Society Act, which, among other provisions, required the President to impose sanctions on individuals identified as responsible for significant acts of violence, serious human-rights violations, or anti-democratic actions.
The European Approach
The European Union’s approach represents a more targeted framework than that of the United States. As of January, 2025, the E.U. maintains sanctions against sixty-nine individuals, with restrictive measures including asset freezes and travel bans. E.U. sanctions focus on key power holders rather than broad sectoral measures. The most recent expansions, in January, 2025, encompassed fifteen additional officials from the National Electoral Council, the judiciary, and security forces in response to post-election repression. These measures include an arms embargo and restrictions on travel to E.U. member states.
Canada’s Escalating Regime
Canada has gradually expanded its sanctions regime and, as of March, 2025, maintains designations against a hundred and thirty-nine individuals. Canadian sanctions have been imposed through six separate rounds since September, 2017, targeting government officials involved in the erosion of democracy, human-rights violations, and electoral fraud. The most recent designations, in March, 2025, encompassed eight high-ranking officials associated with post-election repression following the July, 2024, elections. Canada’s approach focuses on individual asset freezes and transaction bans without imposing sectoral restrictions.
Other Nations
Several other nations have implemented targeted sanctions regimes. Mexico froze assets and imposed travel bans on Venezuelan officials in 2018. Switzerland imposed an arms embargo along with asset freezes and travel bans beginning in 2018-19. Panama imposed targeted sanctions against Venezuelan individuals and entities in 2018 deemed to pose money-laundering or terrorism-financing risks.
Coördinated Action and Recent Developments
In January, 2025, the United States, the E.U., Canada, and the United Kingdom announced coördinated sanctions against Venezuelan officials following the contested reinauguration of Nicolás Maduro—the most significant multilateral action since the disputed 2024 elections. This coördination demonstrates enhanced international alignment, with Canadian and E.U. designations largely mirroring individuals previously sanctioned by the U.S., creating a more effective sanctions web.
The Trump Administration’s approach in 2025 represented a significant shift toward what officials characterized as “maximum pressure,” reversing the limited concessions granted during the Biden Administration.
The Two-Billion-Dollar Question: Venezuelan Gold in British Vaults
The pursuit of Venezuela’s gold—approximately two billion dollars’ worth sitting in the vaults of the Bank of England—has become a legal odyssey worthy of Dickens. On a Friday in late 2024, President Nicolás Maduro’s efforts to seize control of this treasure suffered a setback when the English Court of Appeal dismissed his administration’s appeal and remanded it back to the Commercial Court.
The Court of Appeal rejected the Maduro government’s appeal, ruling that the Commercial Court must determine the case’s future trajectory based on the fact that opposition leader Juan Guaidó is no longer recognized by the British government as Venezuela’s president. The gold stored in the Bank of England’s vaults represents a substantial portion of Venezuela’s $5.2 billion in international reserves, excluding International Monetary Fund special drawing rights, to which the country currently has no access.
Maduro and Guaidó have been battling in court for control of the gold. The legal struggle grew more Byzantine after Guaidó—who, in 2019, was recognized as Venezuela’s legitimate president by dozens of governments worldwide—was removed from his position by allies in January, creating uncertainty about who represents the country’s interests.
The Anatomy of Evasion: How Venezuela’s Government Uses Offshore Companies to Circumvent American Sanctions
The regime’s techniques for evading sanctions were laid bare in a U.S. civil-forfeiture complaint concerning a Dassault Falcon 900EX private jet used by President Nicolás Maduro. The case provides a master class in the sophisticated methods of circumventing international sanctions employed by sanctioned regimes.
The Phantom Entity in St. Vincent and the Grenadines
The aircraft (serial number 007, tail number T7-ESPRT) was smuggled out of the United States using an elaborate scheme centered on a shell company established in St. Vincent and the Grenadines. This phantom entity was conjured into existence mere months before the thirteen-and-a-quarter-million-dollar purchase of the jet. What particularly reveals the instrumental nature of this structure: the company was later struck from the national corporate registry for failure to pay annual fees, confirming that its sole purpose was to execute the one-time aircraft acquisition.
The choice of St. Vincent and the Grenadines as the jurisdiction of registration was not accidental. This nation belongs to the Caribbean offshore jurisdictions characterized by liberal company-registration regulations, limited ownership-structure transparency, and minimal reporting requirements, making it attractive to entities wishing to conceal the true beneficiaries of transactions.
Multi-Layered Financing Structure
The financing network for the transaction was as complex as the corporate structure itself. Funds for the aircraft purchase originated from multiple wire transfers from various countries, including Malaysia, utilizing both U.S. dollars and euros. Such multi-directional flow of funds was designed to obscure the trail of capital origins and complicate law-enforcement efforts to identify the true source of financing.
The use of transfers from multiple jurisdictions, in different currencies, and presumably through different financial institutions, constitutes a classic layering technique employed in money laundering and sanctions evasion. Each transaction layer increases the difficulty of conducting an effective audit of the money trail and identifying the ultimate beneficiaries.
Operational Errors: A Case Study in Unprofessional Execution
Despite the scheme’s sophistication, the complaint reveals a series of operational errors committed by the conspirators that ultimately contributed to the operation’s detection. The conspirators attempted to conceal their Spanish-speaking origins by using e-mail accounts with U.A.E. (United Arab Emirates) domains. However, they slipped up, sending messages containing the telltale Spanish automatic signature “Enviado desde mi iPhone” (Sent from my iPhone).
This seemingly trivial technical detail proved to be significant evidence in the investigation, demonstrating that even in sophisticated sanctions-evasion schemes, human errors and operational oversights can lead to the unmasking of the entire construction. The incident also shows that contemporary sanctions-evasion investigations increasingly rely on digital-metadata analysis and minor inconsistencies in electronic communications.
Officials Convicted of Sanctions Evasion
The case of George Semerene illustrates the United States’ serious approach to sanctions enforcement. Semerene, a sixty-one-year-old Venezuelan and former P.D.V.S.A. official, was sentenced to thirty months in federal prison for orchestrating a sophisticated scheme to circumvent American sanctions and smuggle aircraft parts to Venezuela’s state oil company.
The scheme involved establishing front companies in Costa Rica and Spain, creating false end-user certificates, filing false customs declarations, smuggling parts through third countries, and using Florida-based freight forwarders. Particularly striking is the fact that even after specific P.D.V.S.A. aircraft were sanctioned by O.F.A.C. in January, 2020, Semerene, just three days later, continued pressing for urgent parts orders.
The Justice Department’s message was clear—as Deputy Secretary Matthew Axelrod put it: “The only orders he’ll be placing now are at the prison commissary.” The case demonstrates how seriously the United States treats sanctions enforcement. Semerene is only one of ten defendants in this conspiracy. The others include Venezuelan military officers and directors of companies from Costa Rica and Spain.
The Hybrid State: When Government and Crime Become Indistinguishable
The Maduro government in Venezuela has created what experts call a “hybrid state,” blurring the boundaries between state structures and organized crime. Hybrid regimes are characterized by a combination of autocratic and democratic features, often found in developing countries possessing abundant natural resources. Despite social unrest, these regimes can remain stable for decades. A disturbing trend has been the rise in the number of hybrid regimes since the end of the Cold War.
Venezuela’s Transformation into a Narco-State: The Case of Hugo Armando Carvajal Barrios, “El Pollo”
The guilty plea of Hugo Armando Carvajal Barrios, known as “El Pollo” (The Chicken), reveals a chilling blueprint for Venezuela’s transformation into a narco-state. This case provides unprecedented insight into state-sponsored narcotics-trafficking operations in which cocaine was weaponized against the United States. This is not a story of corrupt officials operating on the margins of the system—it is the revelation of a systematic transformation of the state apparatus into a mechanism for international drug trafficking.
Systematic Architecture of State Corruption
Carvajal Barrios served as director of Venezuela’s military-intelligence agency (D.I.M.—Dirección de Inteligencia Militar) during two critical periods: 2004-11 and 2013-14. His position provided ideal cover for organizing massive narcotics operations under state protection. This was not private criminal activity hidden from state structures—it was a systemic program implemented using the resources and authority of the Venezuelan state.
Carvajal’s position at the head of military intelligence gave him access to all the tools of the national-security apparatus: control over border operations, access to intelligence on law-enforcement activities, the ability to utilize military transportation and communications, and—most important—the capacity to eliminate competing criminal groups while simultaneously protecting “authorized” narcotics operations.
“Cartel de Los Soles”: The Militarization of Drug Trafficking
The indictments reveal how the “Cartel de Los Soles” (named for the sun insignia on Venezuelan military uniforms) systematically corrupted Venezuela’s institutions—the military, intelligence services, legislature, and judiciary—to facilitate cocaine trafficking. The cartel’s name is itself eloquent: it refers to high-ranking officers of the Venezuelan armed forces, whose ranks are symbolized by golden suns on their epaulets. This was not a loose criminal group—it was a structural element of Venezuela’s military and intelligence command.
The Cartel de Los Soles represented a new form of criminal organization: not a group operating in opposition to the state but one integrated with the highest echelons of the state apparatus. Cartel members did not need to hide from authorities—they were the authorities. They possessed state legitimacy, budgetary resources, military equipment, and—crucially—immunity from criminal prosecution within the Venezuelan legal system.
The systematic corruption of individual state institutions was multi-layered. In the armed forces, high-ranking officers not only tolerated drug trafficking but actively participated in it, using military resources to protect shipments. In intelligence, operational information was used to warn smugglers of international law-enforcement actions. In the legislature, any attempts at anti-corruption reforms and strengthening judicial independence were blocked. In the judiciary, cartel members were assured impunity through dismissal of proceedings or issuance of symbolically lenient sentences.
Strategic Partnership with the F.A.R.C.
The most alarming element revealed in the case files is the documented alliance between Venezuelan officials and the F.A.R.C. terrorist organization (Fuerzas Armadas Revolucionarias de Colombia—Revolutionary Armed Forces of Colombia). This was not merely a transactional agreement between parties conducting trade—it represented a calculated strategy to “flood” the United States with cocaine while simultaneously supporting terrorist activities.
The $1.2 Billion P.D.V.S.A. Money-Laundering Scheme: How a Television-Network Owner Built a Massive Money-Laundering Operation
A fascinating case prosecuted by federal prosecutors in Miami reveals how a Venezuelan media mogul transformed currency exchange into a massive money-laundering operation worth more than a billion dollars. The case provides extraordinary insight into the mechanisms of corruption at the highest levels of the Venezuelan state and the sophisticated money-laundering techniques exploiting the international financial system.
Principal Actors in the Scheme
Raúl Gorrín Belisario—the Venezuelan television-network owner and central organizer of the entire scheme. Gorrín was not a typical criminal operating underground—he was a prominent figure in Venezuela’s business and media world, which provided him access to the highest circles of power and credibility in the international financial system.
“Los Bolichicos”—a group of well-connected Venezuelan businessmen with direct contacts at the highest government levels. The term “bolichicos” in the Venezuelan context refers to young, wealthy businessmen from elite families, often connected to the Chávez and Maduro regimes. Their significance in the scheme lay not so much in technical knowledge as in the ability to open doors within state structures and ensure political protection for operations.
P.D.V.S.A. Officials and Financial Managers—a group of state oil-company officials who, by virtue of their positions, had the ability to approve transactions worth hundreds of millions of dollars. Their participation was crucial, because without formal approval from the appropriate P.D.V.S.A. authorities, the entire scheme could not function as an ostensibly legitimate business operation.
A Network of Professional Fund Managers in Europe—sophisticated financial specialists operating in prestigious banking institutions who provided technical handling of cash flows, creation of corporate structures, and camouflaging of the true nature of transactions. Their involvement demonstrates that the scheme was not a primitive criminal operation but a refined enterprise utilizing the highest-class financial services.
