Nevertheless, financial institutions, as well as shipping companies and many other businesses operating internationally, routinely go above and beyond the declared ambit of the sanctions, shying away from authorizing certain transactions out of an abundance of caution or fear of risking hefty penalties. For instance, it was due to US sanctions that COVAX, the global COVID-19 vaccine-sharing initiative backed by the World Health Organization, delayed sending vaccines to Venezuela, although the Venezuelan government had paid in full for the vaccines in advance. At the time, the US State Department dismissed the notion that it bore any responsibility. In any case, Venezuela finally received its first shipment through COVAX only in September, the last country in South America to get it.

Alena Douhan, the United Nations’ special rapporteur on the negative impact of unilateral coercive measures on human rights, has also drawn attention to the issue. In February, after her visit to Venezuela, she issued a preliminary report on the effects of foreign-imposed illegal sanctions on Venezuela, calling existing humanitarian exemptions “ineffective and inefficient” and stating that the “devastating effect” of sanctions is “multiplied by extra-territoriality and over-compliance.” Douhan has also specifically criticized Novo Banco: in July, she, along with other UN officials, sent a letter to the bank, criticizing its “growing over-compliance, zero-risk policies” and reminded the Portuguese lender that EU member states are prohibited by law from complying with US sanctions.

While debates may continue over who bears responsibility, it is clear the broader economic and public health picture in Venezuela remains bleak. About 5 million people have been forced to migrate out of the country in recent years, according to the UN High Commissioner for Refugees. According to even the US government’s own USAID agency, 7 million Venezuelans are in need of humanitarian assistance.

Thus far, the Biden administration has shunned calls to significantly change the Trump-era approach to Venezuela. In a joint statement issued in June alongside the EU and Canada, the US has declared that it would consider easing sanctions on Venezuela if “meaningful progress” is made in talks between the opposition sectors and the government. This month, representatives of the Venezuelan government and the extreme right sector of the opposition have held three rounds of dialogue in Mexico City, hosted by Mexico, mediated by Norway, and accompanied by Netherlands and the Russian Federation. As the November 21 regional elections approach, President Maduro has applauded progress in talks, while a statement issued by Norway’s foreign ministry on September 27 explained that the two sides have adopted joint positions on a number of important issues.