In 2026 the United States authorised business with Venezuela and, for a time, with Iran by general licence. For companies in the EU this means little as long as EU law and the licence conditions do not fit. A situation report on two countries moving in opposite directions.
Iran: UN and EU sanctions remain in force
At the request of France, Germany and the United Kingdom, UN sanctions on Iran returned at the end of September 2025; the EU reintroduced its measures on 29 and 30 September 2025 (among them Regulation (EU) 2025/1975). After the war that began at the end of February 2026 and the ceasefire of 8 April, the presidents of the United States and Iran signed a memorandum of understanding on 17 June 2026. On 22 June OFAC issued General License X for dealings in Iranian oil, valid until 21 August 2026; whether it has been extended must be checked with OFAC before any use. The US trade embargo, hundreds of listings and most statutory sanctions remain. According to the law firm Gibson Dunn, the EU is keeping its sanctions in place for now.
Venezuela: broad US licences, narrow conditions
After the end of the Maduro government in January 2026 and a reform of the hydrocarbons law on 29 January, OFAC issued a series of general licences: GL 46 for oil, GL 47 for diluents, later licences for mining and gold (GL 51D), telecommunications and investment negotiations among others, most recently GL 46E of 28 September and GL 60A for earthquake relief of 16 October 2026. GL 46 initially applied only to US companies established before 29 January 2025; payments to blocked parties go to an account designated by the US Treasury. How companies outside the United States can take part is unclear, according to the law firm Holland & Knight. Executive Order 13884 of 2019, which blocks the property of the Government of Venezuela, is still listed on OFAC’s page. The EU keeps its own regime with an arms embargo and listings (Decision (CFSP) 2017/2074).
What follows for companies in the EU
- A US licence does not permit anything EU law prohibits. For Iran, check EU law first.
- A US licence applies only within its wording and its term. Before relying on one, retrieve the current version from OFAC.
- Since 2018 the Blocking Statute has covered several US laws on Iran, but none on Venezuela. Anyone complying with US law on Iran should review this with their own legal adviser.
- Banks and insurers often decide more cautiously than the law requires. Present licence text, contract and payment route together and early.
This report is not legal advice for individual cases.
Sources
- Gibson Dunn, „The U.S.-Iran Memorandum of Understanding: Prospective Sanctions Relief, Commercial Opportunities, and Legal Risks“, 2026, https://www.gibsondunn.com/us-iran-memorandum-of-understanding-prospective-sanctions-relief-commercial-opportunities-and-legal-risks/
- Mayer Brown, „EU Reintroduces Sanctions Against Iran Following UN Snapback“, 3.10.2025, https://www.mayerbrown.com/zh-hans/insights/publications/2025/10/eu-reintroduces-sanctions-against-iran-following-un-snapback
- The National, „All eyes on Strait of Hormuz as Iran and US agree to ceasefire“, 8.4.2026, https://www.thenationalnews.com/business/energy/2026/04/08/all-eyes-on-strait-of-hormuz-as-iran-and-us-agree-to-ceasefire
- Holland & Knight, „OFAC Authorizes Certain Venezuelan Oil Sector Activities Following Venezuelan Reform“, February 2026, https://www.hklaw.com/en/insights/publications/2026/02/ofac-authorizes-certain-venezuelan-oil-sector-activities
- US Treasury (OFAC), Venezuela-Related Sanctions, Recent Actions to 16.10.2026, https://ofac.treasury.gov/sanctions-programs-and-country-information/venezuela-related-sanctions
- Commission Delegated Regulation (EU) 2018/1100 amending the Annex to Regulation (EC) No 2271/96, https://eur-lex.europa.eu/eli/reg_del/2018/1100/oj
All online sources accessed on 3 November 2026.