Search

Home > FCPA Compliance Report > Venezuela Re-Entry: A Strategy of Watchful Waiting
Podcast: FCPA Compliance Report
Episode:

Venezuela Re-Entry: A Strategy of Watchful Waiting
Category: Business
Duration: 00:26:01
Publish Date: 2026-03-02 05:00:00
Description:

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Morgan Lewis partners Carl Valenstein (international corporate law, Latin America) and Katelyn Hilferty (international trade, export controls and sanctions) on whether businesses should consider returning to Venezuela after Maduro’s arrest and President Trump’s announcement. Ed. Note: this podcast was recorded in February, and since then, OFAC has issued New and amended Venezuelan-related General Licenses. The situation remains fluid.

Valenstein leads off by noting that he is counselling businesses to engage in “watchful waiting” due to continued instability, corruption, weakened institutions, security risks, uncertainty about elections, and a lack of clear U.S. incentives, such as political risk insurance. Hilferty explains that sanctions relief is narrow: two limited OFAC general licenses focused on Venezuelan-origin oil and U.S.-origin diluents, while most sanctions and broad export control restrictions remain in effect, with licenses revocable. They discuss payment and transparency concerns, large outstanding debts, and major capital and operational challenges to restore oil production. They advise companies to review licenses, establish compliance guardrails, screen counterparties, and draft contract and payment terms before pursuing opportunities.

Key highlights:

  • What Changed in Venezuela
  • Watchful Waiting Reality Check
  • License Reversals and Uncertainty
  • Compliance Starting Point Checklist
  • Cartels and Terror Designations
  • Beyond Oil and Gas Opportunities

Resources:

Morgan Lewis

Carl Valenstein

Katelyn Hilferty

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Returning to Venezuela on Amazon.com

Learn more about your ad choices. Visit megaphone.fm/adchoices
Total Play: 0

Some more Podcasts by Thomas Fox

200+ Episodes
10 For 10