Venezuela sanctions: Switzerland freezes, U.S. unfreezes, EU has until January 10

Because the Swiss list that moved is not a sanctions list. Switzerland has two lists on Venezuela, with different laws, purposes and authorities.

The one that changed is a freeze ordered by the Federal Council on January 5 under the Foreign Illicit Assets Act (FIAA), "en vue de l’entraide judiciaire": so that the assets stay where they are if a request for judicial cooperation to recover them arrives. It expires on January 4, 2030, and since October 16 it lists 41 people. When it was issued, the Federal Council wrote that it does not affect members of the current Venezuelan government and that it targets people who had not previously been sanctioned in Switzerland. The first name in the annex is Nicolás Maduro.

The other is the sanctions list, under the Embargo Act, in force since 2018. It has 69 people, the same as the European Union, marked "Origin: EU," and its annex has not changed since January. Delcy Rodríguez and Diosdado Cabello are still on it.

Only one of the eight names has the same status on all five lists: Jorge Rodríguez, who since October 14 appears on none.

In the United States, OFAC writes that no license is needed to unblock the property of someone removed from its list. That removal has no effect in any other jurisdiction.

A bank subject to EU law is still required to freeze the funds of the 69 people in the annex and not to make resources available to them, directly or indirectly. The regulation reaches any business done in whole or in part within the Union, and requires reporting frozen accounts to the member state's authority. In Switzerland, the embargo list requires declaring without delay to the State Secretariat for Economic Affairs and reporting balances as of December 31 every year by February 15. The freeze list requires notifying the money laundering reporting office, and anyone who releases those assets without authorization faces up to three years in prison. The Swiss supervisor reminded financial intermediaries on October 16 that they must freeze and report without delay.

The document does not say. The amendment by the Federal Department of Foreign Affairs, signed on October 14, merely repeals their two entries, and cites the article of the law that allows a person to be removed for two different reasons: that coordination with the main partners or the defense of Switzerland's interests requires it, or that the freeze proves unfounded. The explanations that circulated, such as that they had no assets in Switzerland, do not come from any official document. What is on record is that both remain on OFAC's list.

It describes him as a former minister of Industry and National Production and former president of the International Center for Productive Investment, posts it dates between 2024 and 2026, and adds Álvaro Pulido as his associate. Both have been on OFAC's list since 2019. In the United States, Saab received clemency in December 2023; in a new case in Miami he pleaded guilty to one count on September 15, 2026, and sentencing is set for January 20, 2027.

That day the European Union's measures expire, extended by a Council decision of December 15, 2025. Before that date the 27 member states have to decide whether to renew them and with which names. The regulation's criteria are human rights violations, repression of civil society and the opposition, and actions that undermine democracy or the rule of law.

The decision does not stay in Brussels. The Swiss embargo list follows the European one: in January 2026, the only amendment to its annex updated the same four entries the Council had changed a month earlier. Washington decided on the acting president in April. For a European or Swiss bank, the date that decides is on Brussels' calendar.