The judicial files from the United States Department of Justice allow for the reconstruction of over a decade of corruption patterns within Petróleos de Venezuela: businesspeople who paid to be included on supplier lists, officials who altered contracting processes and payment priorities, intermediaries who concealed bribes through fictitious consultancies, and companies that received confidential information to gain an edge against rivals. In 2026, Washington has reopened avenues for oil operations in Venezuela, but under much stricter controls. The challenge now is to determine if the old networks within PDVSA are trying to adapt to the new system.
For years, corruption in PDVSA was portrayed as a series of isolated scandals. A businessman bribed an official. A manager favored a supplier. A company obtained a contract. An intermediary popped up between Petróleos de Venezuela and the end beneficiaries. Ultimately, part of the money ended up outside the country.
The criminal files from the U.S. Department of Justice identified recurring mechanisms for capturing different stages of PDVSA’s contracting system, from supplier selection to contract awarding, access to internal information, and priority in payments.
These findings take on new significance in 2026 when the United States again permits certain oil operations in Venezuela through licenses from the Office of Foreign Assets Control, OFAC, and Chevron, BP, Eni, Repsol, Shell, and Maurel & Prom are specifically included in the newly authorized scheme.
One of the aspects generating controversy is whether this U.S.-supervised process in the Venezuelan oil industry can radically change the business and administrative structures that have been key players in the corruption scandals subject to investigation in U.S. courts. This also implies that those companies or their branches are attempting to become suppliers, contractors, or partners of the international companies operating within the new system.
Corruption in PDVSA: Paying to Get on the Supplier List
One of the most revealing cases was confessed in front of the U.S. justice system by Venezuelan-American businessman Roberto Enrique Rincón Fernández. In June 2016, the Department of Justice announced that Rincón pleaded guilty to charges related to a bribery scheme aimed at securing contracts with PDVSA.
His confession illustrates that corruption could start even before a contract was awarded. Rincón admitted that he and Abraham Shiera agreed to pay bribes and provide other benefits to PDVSA procurement analysts to ensure their companies were added to the bidding panels of the Venezuelan oil company.
He also acknowledged paying other officials to ensure his companies were included in the lists of suppliers approved by PDVSA.
This mechanism had an extraordinarily significant consequence. A company could formally appear authorized to contract with PDVSA. It could submit bids and receive contracts. From the outside, the process could seem like standard administrative procedures. But the initial access had been bought through bribery.
Therefore, currently investigating PDVSA contractors requires going beyond just determining if a company was registered as a supplier. The review must include, among other things, how the company obtained that position, who facilitated its incorporation, and which officials were involved in the process.
The Business of Collecting PDVSA Invoices First
The Rincón case revealed another mechanism. During the years of PDVSA’s financial decline, obtaining a contract did not necessarily mean quick payment. The company accrued obligations to numerous suppliers. This situation created another opportunity for corruption: controlling the order of payments.
Rincón admitted to bribing PDVSA officials to ensure that his companies received priority in the payment of outstanding invoices, placing them ahead of other suppliers.
Other federal files documented additional schemes in which entrepreneurs paid bribes to Venezuelan officials in exchange for contracts and priority in collecting the invoices owed by PDVSA. In other words, when cash was tight, controlling the order of payment could become as significant a business transaction as controlling contract awards.
Insider Information: Knowing the Business Before Competitors
Another mechanism emerged in the criminal process against Sargeant Marine Inc. In September 2020, the company pleaded guilty to conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act, FCPA, for schemes developed in Brazil, Venezuela, and Ecuador.
Sargeant Marine agreed to pay approximately 16.6 million dollars to resolve the criminal process. The Federal Prosecutor’s Office for the Eastern District of New York reported that the company generated approximately 8.2 million dollars in profit from the Venezuelan scheme.
However, the bribes did not just buy decisions but also could purchase information. According to the Department of Justice, the scheme permitted gaining non-public information from PDVSA officials, providing a corrupt advantage over other competitors.
This mechanism once again becomes crucial in 2026. As international companies seek suppliers, personnel, infrastructure, and opportunities within Venezuela, knowing in advance which contracts will be awarded, which fields need investment, what are the technical requirements, or what the conditions for a contract will be, can be worth millions of dollars.
Corruption does not always need to manipulate a public tender; in many documented cases, it began with someone who knew the information before others.
Fictitious Consultancies and False Invoices to Conceal Bribes
The Sargeant Marine case also allowed the DOJ to establish how money could be concealed. The company used fictitious consultancy contracts and false invoices to disguise specific corrupt payments. Part of the money passed through offshore accounts controlled by intermediaries before reaching the scheme’s recipients.
The structure could appear to be an ordinary business operation, starting with the contractor, intermediary, consultancy, invoice, payments to a foreign account, and a government official in exchange for a contractual benefit. The existence of commercial documentation didn’t prove that there was a legitimate service behind the payment.
This precedent is especially important for analyzing current oil services companies because an invoice, a service order, or a consultancy contract does not automatically prove that the contracted work was completed. Verification requires comparing the documentation with the actual execution.
Corruption Also Operated from Within
The U.S. files reveal that many schemes would have been impossible without the involvement of internal officials. In 2018, Abraham Edgardo Ortega, former executive director of financial planning at PDVSA, pleaded guilty in U.S. court.
The Department of Justice reported that Ortega admitted to receiving 5 million dollars in bribes related to specific financial operations and another 12 million dollars for his participation in a different scheme related to PDVSA funds.
Subsequently, the U.S. investigated another massive scheme involving approximately 1.2 billion dollars from PDVSA, which was the subject of international money laundering operations.
The pattern was recurrent, as PDVSA provided the asset, the official could provide the decision, and then get the businessman to supply the private structure, with the financial system enabling the movement of money.
PDVSA Remains Sanctioned by the U.S.
The new Venezuelan scenario has not eliminated a fundamental legal fact: PDVSA continues to be a blocked entity by the United States. OFAC formally sanctioned Petróleos de Venezuela on January 28, 2019, under Executive Order 13850.
However, in 2026 Washington expanded possibilities for certain oil operations through a licensing system. On June 10, 2026, OFAC issued General License 50B, allowing certain oil and gas operations in Venezuela for a specific group of international companies.
The companies expressly included are BP, Chevron, Eni, Maurel & Prom, Repsol, and Shell. These changes should not be understood as a general lifting of restrictions against PDVSA. We are talking about a regulated opening.
OFAC Seeks to Introduce Traceability in Venezuelan Oil
The conditions set by the United States are especially revealing when compared to the documented corruption mechanisms from previous years. General License 50B establishes requirements concerning certain contracts, payments, jurisdictions, and approved operations.
Washington has not merely allowed some large oil companies to return or expand activities in Venezuela. It is trying to build a structure where who participates in operations and how money circulates can be better known.
The judicial records help to explain this caution. The United States is well aware of the corruption background associated with PDVSA because its prosecutors have investigated for years how those networks operated.
Chevron and the Hidden Risk in PDVSA’s Contractor Chain
The primary risk is not necessarily found within the large international companies. Chevron, Shell, BP, Repsol, and Eni have international compliance systems and are subject to anti-corruption laws from various jurisdictions, but no major oil company can operate alone in Venezuela.
Beneath each project lies an extensive chain of contractors and subcontractors. Electricity, generation, instrumentation, pumps, pipes, transportation, maintenance, security, construction, engineering, logistics, and personnel are all part of that ecosystem.
Each company can become a supplier, and each supplier can hire another. This presents one of the main challenges for the new Venezuelan oil industry. Due diligence cannot stop at PDVSA or the international company, but must extend to the Venezuelan companies seeking to place themselves between PDVSA and the new international operators.
A Company Can Disappear While the Network Remains
The corruption records also require investigating more than just brand names. One company can close and another can appear. Shareholders can change, for instance, by adding a family member, creating a company in Florida or elsewhere, or bringing in a foreign partner. A corporate identity can disappear without the individuals controlling the business vanishing. Thus, a true oil due diligence in Venezuela cannot limit itself to asking about a company’s name; it must determine who the beneficial owner is and who it was previously.
The corporate history matters just as much as the current structure. Service orders: the next territory to be investigated exists in a space particularly vulnerable within PDVSA: service contracts and the so-called service orders, ODS.
The official U.S. files examined do not allow us to assert that current complaints about certain service orders in San Tomé or in the Orinoco Oil Belt have been substantiated. This distinction is critical since the mechanisms proven by the DOJ help establish exactly what an investigation should be searching for.
Each operation should be reconstructed based on a pattern reviewed by the Department of Justice, a service order from a company submitting a budget for physical execution that requires a certification under a payment authorization invoice going to a receiving account and a final beneficiary.
An invoice merely proves that someone billed; it does not necessarily indicate that the work existed. To establish that, one must compare the money paid with the physical execution that supposedly justified that payment.
NABEP and the New Venezuelan Oil Map
Within the new oil scenario in Venezuela, the controversial firm North American Blue Energy Partners, NABEP appears, which is not listed among the companies expressly included in the OFAC General License 50B annex. This does not imply that NABEP has committed any illegality or that any dealings involving the company are prohibited.
It means that its situation and any transactions involving blocked entities must be analyzed according to the specific applicable authorizations, licenses, and legal structure. In regulatory compliance investigations, a company’s absence from a particular license does not constitute an accusation, but this fact cannot be overlooked.
The China Factor in OFAC’s New Rules
General License 50B introduces another particularly relevant issue for rebuilding the Venezuelan oil sector. The license establishes exclusions for certain operations related to individuals located in Russia, Iran, North Korea, Cuba, or the People’s Republic of China, as well as certain ownership, control, or association structures linked to those actors. This makes identifying the ultimate beneficial owner of Venezuelan contractors a legal necessity.
A company may have a Venezuelan name, a Venezuelan address, and Venezuelan directors, but still maintain foreign ownership or control structures that are relevant for U.S. sanctions compliance.
The Five Vulnerable Points Revealed by PDVSA’s Corruption Cases
The processes documented by the U.S. Department of Justice allow for the identification of five critical points of vulnerability within Venezuelan oil contracting: supplier registration, contract awarding, internal information access and use, administrative certification, and payment execution. These five links should form the backbone of any new system of oversight, transparency, and compliance applied to PDVSA and the oil sector.
The United States has important tools to monitor part of the international flows of money, impose regulatory obligations, investigate and pursue bribery schemes when there is U.S. jurisdiction, and establish conditions for companies authorized to operate in Venezuela. However, that control has an evident limit: Washington is not physically present in every PDVSA office, oil facility, warehouse, technical management, or contracting process executed within Venezuelan territory. The everyday oversight of these spaces, the prevention of irregularities, and the ability to detect new corruption networks ultimately depend on the rebuilding and strength of Venezuelan institutions.
Corruption Can Survive the Political System That Created It
One of the greatest risks of any political transition is the assumption that the economic networks tied to corruption automatically disappear with a change of power. These structures have a tremendous capacity for adaptation because they accumulate years of knowledge, relationships, and experience within the system: they know the administrative procedures, the officials, the oil fields, the suppliers, the operational needs, the control gaps, and the mechanisms of contracting, billing, and payment.
A political change may remove a minister, replace the PDVSA board, or transform the formal structure of the state, but that does not necessarily dismantle the networks operating beneath those positions. A contractor who has been around the same oil facility for fifteen years can outlast various governments, boards, and reforms, retaining enough contacts, insider information, and operational knowledge to adapt to the new scenario and, eventually, reproduce the same corruption mechanisms under new power structures.
The U.S. Now Faces a Different Battle Within PDVSA
In 2026, the United States established a new control architecture around Venezuelan oil: OFAC allows certain operations under specific conditions for international companies while maintaining restrictions on PDVSA. However, the history documented by the Department of Justice itself demonstrates that corruption within the Venezuelan oil industry did not solely depend on the decisions made at PDVSA’s presidency or the highest political levels. The schemes could also operate from intermediate and operational levels: all it took was an official capable of incorporating a company into the supplier system, another willing to provide insider information, someone to authorize a contract or certify a service, an invoice, an intermediary, a bank account, and finally an official with the capacity to order or facilitate payment. For this reason, reconstructing the Venezuelan oil industry will demand much more than just recovering infrastructure and boosting production; it will be necessary to rebuild integrity, traceability, and transparency in PDVSA’s contracting system.
The real test for Chevron, the other international companies, Washington, and the Venezuelan authorities will not simply be determining how many barrels Venezuela can produce again, but preventing the same networks that learned to turn PDVSA contracts into private sources of money, influence, and power from reappearing, recycled through new companies, shareholders, contractors, and intermediaries. The Department of Justice’s records show that these mechanisms existed, while the new conditions imposed by OFAC reflect that Washington recognizes the risks associated with reopening the sector. Therefore, the next level of scrutiny must focus on a decisive question: who survived the old structure, which companies currently control it, and which are trying to integrate into the new Venezuelan oil industry using contracts, partnerships, or operations linked to authorized international companies as a cover.