On Venezuela Investment — Opportunity or Siren Song?
Corporate Compliance Insights
In this article, Matteson Ellis and Collmann Griffin examine the growing interest in Venezuela's energy sector following recent U.S. sanctions developments. They outline a three-step roadmap for initial investment, including ensuring compliance with Office of Foreign Assets Control (OFAC) general licenses, developing security and compliance protocols, and advancing operational planning. The authors emphasize the complexity of navigating evolving regulatory requirements and heightened risk exposure, noting that "companies should anticipate that bribery, money laundering, cartel and antiterrorism threats and sanctions risks will be pronounced, and they should plan accordingly." They also highlight the importance of aligning compliance strategies with U.S. government expectations to mitigate long-term enforcement risk.