Treasury Targets Oil Traders Engaged in Sanctions Evasion for Maduro Regime

Date issued: Dec. 31 2025

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TURBOFAC Commentary (159 words)

Notes:

1) While the Press Release is entitled "Treasury Targets Oil Traders Engaged in Sanctions Evasion for Maduro Regime," thereby suggesting a degree of inherent nefariousness that would take the designations out of the realm of "de facto secondary sanctions" (Introductory Note Common to all Derivative Designation Notices ("De Facto" Secondary Sanctions) Included in the Research System (System Ed. Note)), this Press Release is notable as the second since the first Trump Administration to sanction tankers for transporting Venezuelan oil (compare Treasury Targets Illegitimate Maduro Regime Insiders and Sanctions Evaders in Venezuela’s Oil Sector (Press Release)). Here, OFAC targets " four companies for operating in Venezuela’s oil sector and identified four associated oil tankers," including under circumstances where no deceptive conduct was alleged. These appear to be straightforward “de facto secondary sanctions” actions, but to the extent they aren’t, they serve...