VENEECONOMIST
Analysis Type C — Sectoral · OCTOBER 19, 2026

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

OFAC removed Jorge Rodríguez from its list on October 14, 2026, and Switzerland added Alex Saab and Álvaro Pulido to its own, which is an asset freeze for judicial cooperation, not a sanction. Delcy Rodríguez remains subject to an asset freeze in the European Union, the United Kingdom and under the Swiss embargo list, and the European measures expire on January 10, 2027.

Published October 19, 2026
◆ Risk · Sanctions and compliance Data close: October 18, 2026

On October 14, OFAC removed Jorge Rodríguez, president of the National Assembly, from its sanctions list. Two days later an ordinance took effect in Switzerland that added six names to an asset-freeze list, among them Alex Saab and Álvaro Pulido, and removed those of Jorge Arreaza and Marleny Contreras.

For a bank doing business in Europe, what matters did not move that week: Delcy Rodríguez, off Washington's list since April 1, remains subject to an asset freeze in the European Union, the United Kingdom and Switzerland.

Why does Switzerland add names while Washington removes them?

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.

Who is on which list?

Only one of the eight names has the same status on all five lists: Jorge Rodríguez, who since October 14 appears on none.
Status on each list, October 2026
PersonOFACEUSwitzerland, embargoSwitzerland, freezeUnited Kingdom
Delcy RodríguezNo (removed Apr 1)YesYesNoYes
Jorge RodríguezNo (removed Oct 14)NoNoNoNo
Diosdado CabelloYesYesYesNoYes
Nicolás MaduroYesNoNoYesNo
Alex SaabYesNoNoYes (added Oct 16)Yes, anti-corruption regime
Álvaro PulidoYesNoNoYes (added Oct 16)Yes, anti-corruption regime
Jorge ArreazaYesNoNoNo (removed Oct 16)No
Marleny ContrerasYesNoNoNo (removed Oct 16)No

OFAC, SDN list of Oct 15, 2026 · EU, Regulation 2017/2063 and consolidated list of Oct 15, 2026 · Switzerland, annexes to ordinances SR 946.231.178.5 and SR 196.127.85 · United Kingdom, FCDO list of Oct 16, 2026.

If OFAC delisted someone, can a bank deal with that person?

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.

Why were Arreaza and Contreras taken off the Swiss list?

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.

What does the Swiss list say about Alex Saab?

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.

What changes on January 10, 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.

In the European Union's annex, Delcy Rodríguez's entry still describes her as Vice-President of Venezuela and, since August 2024, Minister of Oil. She has been off OFAC's list for six and a half months.

Sources ▾
  • Swiss Federal Council — Ordinance on the freezing of assets in connection with Venezuela, SR 196.127.85, as of Oct 16, 2026. — fedlex.admin.ch
  • FDFA — amendment to the annex of SR 196.127.85, Oct 14, 2026 (AS 2026 550). — fedlex.admin.ch
  • Swiss Federal Council — SR 196.127.85, version of Jan 5, 2026. — fedlex.admin.ch
  • Swiss Confederation — Foreign Illicit Assets Act, SR 196.1, as of Jul 1, 2016. — fedlex.admin.ch
  • Swiss Federal Council — statement on the asset freeze, Jan 5, 2026. — news.admin.ch
  • FINMA — notice on SR 196.127.85, Oct 16, 2026. — finma.ch
  • Swiss Federal Council — Ordinance on measures against Venezuela, SR 946.231.178.5, as of Jan 13, 2026. — fedlex.admin.ch
  • SECO — annex 1 to SR 946.231.178.5, full version of Jan 13, 2026. — fedlex.admin.ch
  • SECO — annex 1 to SR 946.231.178.5, amendments of Jan 12, 2026. — fedlex.admin.ch
  • Council of the EU — Decision (CFSP) 2025/2586, Dec 15, 2025. — eur-lex.europa.eu
  • Council of the EU — Regulation (EU) 2017/2063, consolidated text as of Dec 17, 2025. — eur-lex.europa.eu
  • OFAC — SDN List deletions, Oct 14, 2026. — ofac.treasury.gov
  • OFAC — SDN List deletions, Apr 1, 2026. — ofac.treasury.gov
  • OFAC — SDN list file, Oct 15, 2026. — treasury.gov
  • OFAC — FAQ 1196 on unblocking after a delisting, Oct 7, 2024. — ofac.treasury.gov
  • FCDO — UK Sanctions List, Oct 16, 2026. — sanctionslist.fcdo.gov.uk
  • U.S. District Court, S.D. Florida — case 1:19-cr-20450, clemency, Dec 21, 2023. — courtlistener.com
  • U.S. District Court, S.D. Florida — case 1:26-cr-20020, guilty plea, Sep 15, 2026. — courtlistener.com
Classification
Analysis Type C — Sectoral
Riesgo · Sanciones y cumplimiento
October 19, 2026
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VENE · ECONOMIST Intelligence Unit · Informational analysis. Does not constitute investment, legal or tax advice. Vene Economist is not a credit rating agency; the "VE Verdict" is a proprietary editorial indicator, not a credit rating. Always verify against the primary source before making decisions.

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