VENEZEULA Trends and Developments Contributed by: Maryna Pogibko, Rafat A Rizvi and Mykhailo Grydzhuk, Amadeus
Conclusion The post-January 2026 Venezuelan hydrocarbon sector is being rebuilt on a legal framework in which US licences, US payment control, US law-governed contracts and US policy priorities shape who partici- pates, on what terms and through which structures. The steps needing to be taken to validate investments may appear daunting, but it is generally accepted that OFAC’s guidelines have brought much-needed clarity to what was previously, according to many, a quag- mire of uncertainty. For sophisticated clients, there is now no reason to stay away. The commercial opportunity is clear. Production vol- umes are rising, counterparties are returning, PdVSA- related business is once again possible, and new, clearly defined investment pathways now exist. But the prize-winning participants are unlikely to be those who treat the country merely as a political thaw. It will be those who understand that, in today’s Venezuela, legal structuring is not a support function: it is the investment strategy itself. The Venezuelan economy is reopening and its key driver, the oil and gas sector, is at the centre of a new friendlier regulatory framework which has been rapidly reshaped by the Trump Administration. This frame- work aims to open the oil sector to opportunity-hungry capital whilst supporting the US’ longer-term domes- tic political considerations. Never has the old adage, “to the victor, go the spoils” been more apt.
products to countries other than the USA. Those reports are due ten days after the first transaction and every 90 days thereafter, while transactions continue. In practice, this means that entry into Venezuela is not a one-time sanctions question. It creates an ongoing compliance process. Non-US parties can participate, but not casually One of the more important clarifications in the 2026 Venezuela framework is that the market is not reserved exclusively to US parties. OFAC FAQ 1247 states that non-US persons generally do not face sanctions risk for engaging in transactions authorised by GLs 46B, 51A and 52, including importing Venezuelan-origin oil into a third country, provided certain conditions are met. These conditions include the use of a qualify- ing non-US entity organised on, or before, 29 January 2025 and commercially reasonable payment terms. This distinction is important for all non-US investors as it means the market is now substantially broader, yet it does not justify a simplistic view that “non-US” automatically means “outside OFAC.” The reality is more exacting. Non-US participation in Venezuela’s re-emerging oil sector is possible, but only within a framework that remains anchored to US payment controls, US policy priorities and, in many cases, US- centric contractual structures.
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