On March 24, 2025, President Donald Trump signed an Executive Order (EO) declaring that any country purchasing oil from Venezuela, “whether directly from Venezuela or indirectly through third parties,” will pay a 25% tariff on their exports to the United States.  The EO tasks the Secretary of Commerce with determining whether a country buys Venezuelan oil.

Referencing the International Emergency Economic Powers Act (IEEPA), President Trump explains in the EO that the 25% tariff is necessary to thwart “Venezuela’s ongoing destabilizing actions, including its support for illicit activities, [which] necessitate further economic measures to protect United States interests.”  According to the EO, the tariff “will be supplemental to duties on imports already imposed pursuant to IEEPA, section 232 of the Trade Expansion Act of 1962, section 301 of the Trade Act of 1964, or any other authority.”

The 25% will take effect on April 2, 2025—the same day Trump is expected to implement a variety of tariff strategies based on reports he is set to receive April 1, 2025, from various trade-adjacent departments and agencies pursuant to his “America First Trade Policy.”  (For background on the “American First Trade Policy,” see Update of January 22, 2025.)  However, “the tariff…shall expire 1 year after the last date on which the country imported Venezuelan oil, or at an earlier date if the Secretary of Commerce…so determinates[.]”

According to a 2024 report and 2023 report by Reuters, China is the largest purchaser of Venezuelan oil; other major buyers include Brazil, Colombia, Cuba, European countries, India, and Panama.  By comparison, the data show the United States is the second-largest purchaser, though the amount bought is expected to decline after the Trump administration announced the winding down of a general license permitting a major U.S. company to transact with Petróleos de Venezuela, S.A. (PdVSA), Venezuela’s state-owned oil and natural gas company (see Update of March 25, 2025).

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Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.