Recent U.S. policy actions have opened a narrow but actionable pathway for compliant engagement with Venezuela. Venezuela is re-emerging as one of the few genuine frontier markets with meaningful scale in energy, technology, and distressed assets, but any re-entry must be tightly structured around sanctions, political risk, and contract durability. These policy shifts have created a narrow, compliance‑driven channel through which Venezuelan crude oil, technology-focused capital, and related financial flows can re-enter global markets, opening space for sophisticated investors who can navigate a complex legal and regulatory landscape.

Momentum is now visible in hard numbers: the United States has completed the first sales of Venezuelan oil under a new arrangement, with initial transactions valued at approximately $500 million as part of a broader $2 billion deal between Washington and Caracas. The revenue from these sales is being held in U.S.-controlled accounts, including a main account in Qatar, reinforcing that Venezuela’s reopening is real but occurring under tight U.S. oversight and conditions.

Diplomatically, the United States has sent a State Department delegation to Caracas to assess conditions for a phased reopening of the U.S. embassy and consular services, signaling a broader effort to normalize engagement and support lawful commercial activity. A restored on‑the‑ground presence would enhance investor access to consular support and real‑time political risk intelligence, which are critical for deploying personnel and capital into a high‑risk environment.

On the corporate front, the administration has pressed leading oil executives to consider large‑scale investment in Venezuela, receiving a cautious response. Exxon’s leadership has characterized Venezuela as "uninvestable," underscoring concerns over historic expropriations and contract security, while Chevron — long the only major U.S. operator continuously active under OFAC licenses — is expanding production and headcount, leveraging existing joint ventures and infrastructure. More adventurous independents and wildcatters are also evaluating entry as the government signals its ambition to position Venezuela as a technology and innovation hub for the Americas.

In this environment, legal structuring and compliance discipline will determine whether opportunity translates into sustainable value—or avoidable exposure.

Akerman advises clients on Venezuela-related developments at the intersection of sanctions, energy, finance, technology, and cross-border risk, with a team that includes lawyers licensed in and with experience in Venezuela and across Latin America.

Our work with Venezuela-focused investments clusters around several core workstreams:

• Sanctions and export‑control compliance
  • Interpreting the evolving U.S. Venezuela sanctions framework and related export controls
  • Structuring activity under OFAC general and specific licenses and designing end‑to‑end compliance programs for ongoing operations
• Energy, commodities, infrastructure, and tech‑adjacent transactions
  • Structuring authorized crude and refined‑product offtake, marketing, transportation, and related logistics tied to Venezuelan production
  • Advising on joint ventures, services agreements, and investment structures for energy, logistics, and technology‑driven projects aligned with Venezuela’s hub ambitions
• Cross‑border structuring and risk allocation
  • Designing corporate, financing, and holding structures that address political risk, sanctions exposure, and tax and regulatory considerations across multiple jurisdictions
  • Embedding robust termination, change‑of‑law, sanctions, anti‑corruption, and dispute‑resolution protections tailored to Venezuela’s volatility
• Asset recovery, disputes, and enforcement
  • Pursuing or defending claims arising from legacy exposure, including expropriations, contract frustration, and unpaid receivables
  • Handling international litigation and arbitration, and enforcing awards and judgments against Venezuelan counterparties and related assets
• Policy analysis, restructuring, and contingency planning
  • Monitoring shifts in U.S. and Venezuelan policy and advising on timing, scenario planning, and exit options for new or renewed investments
  • Restructuring existing positions, dormant contracts, and distressed assets to fit within the new, license‑driven framework
• Dispute resolution
  • Litigation and arbitration of claims against Venezuela and its various government agencies
  • Recovery of monetary claims against identifiable assets in and outside of the jurisdiction

For investors prepared to move deliberately — with disciplined structuring, robust compliance, and a clear view of both upside and risk — Akerman offers the platform to engage Venezuela’s reopening with confidence.

For tailored advice, please contact:

• Corporate: Pedro A. Freyre, Chair, International
  • Arturo H. Banegas Masiá,  Partner (also licensed in Venezuela)
• Litigation: Luis A. Perez, Chair, Latin America and the Caribbean, Co-Office Managing Partner, Miami
• Sanctions: Felicia Leborgne Nowels, Partner, Government Strategies
• Government: LaKeisha C. Marsh, Chair, Government Strategies
• Energy: Scott D. Marrs, Houston Office Managing Partner, Litigation
• Technology: James Grice, Co-Chair, Energy and Infrastructure
• Real Estate: Eric D. Rapkin, Chair, Real Estate
  • Neisen Kasdin, Co-Office Managing Partner, Miami