Curtis Hosts Conference on Venezuela Sanctions and Energy Opportunities in Cartagena

On April 16, 2026, Curtis hosted a conference in Cartagena on the evolving U.S. sanctions regime applicable to Venezuela and its implications for energy, hydrocarbon, and infrastructure companies seeking to evaluate opportunities in the country. The event, organized in partnership with Colombian law firm Serrano Martínez CMA, drew over 45 attendees representing the full spectrum of Colombia's gas industry — producers, transporters, distributors, and traders — many of whom were in the city for the annual Congreso de Naturgas. Demand for seating exceeded expectations, requiring additional chairs to be brought into the room.

The conference, led by Curtis Partner Elisa Botero, addressed a rapidly shifting regulatory landscape that has fundamentally altered the risk and opportunity calculus for companies operating in or considering entry into Venezuela's energy sector.

Key Issues Addressed

The session opened with a framing of sanctions as instruments of foreign policy rather than static legal prohibitions — a distinction critical to understanding how they evolve and how companies must respond. Ms. Botero walked attendees through the transformation in the Venezuela sanctions regime following January 3, 2025, when the U.S. shifted from a near-comprehensive prohibition on energy, infrastructure, and hydrocarbon transactions to a more graduated framework that, while creating space for certain activities, maintains significant barriers to entry — barriers that, by design, favor U.S.-incorporated entities and their partners.

The conference emphasized that this new landscape demands individualized legal analysis. There is no one-size-fits-all answer to whether a given project, transaction, or counterparty relationship is permissible. Companies must assess, on a case-by-case basis, whether a general license covers their specific activity, whether a specific OFAC license is required and obtainable, and what residual risks remain even where a license exists. Operating without that analysis — or with generic guidance not tailored to the specific facts — carries significant legal and reputational exposure.

Curtis' Capabilities in Sanctions, Energy, and Project Finance

Curtis' Economic Sanctions practice brings decades of experience advising companies across industries on U.S., EU, UK, and UN sanctions regimes. The team includes litigation, transactional, and international trade lawyers who work in concert to provide end-to-end guidance — from compliance program design and risk assessments, to the preparation and submission of specific license applications to OFAC, to sanctions diligence in the context of cross-border transactions and project financings.

These capabilities complement Curtis' deep Energy (Oil & Gas) and Infrastructure Development practices, which have advised private companies and project developers on some of the region's most complex transactions, including petroleum and petrochemical projects, LNG and gas infrastructure, pipeline development, and cross-border project financings. The Bogotá office serves as Curtis' hub for the Latin American energy, infrastructure, and corporate practice, with direct connectivity to the firm's New York, Washington, D.C., and London offices.

For energy and infrastructure companies evaluating opportunities in Venezuela — whether in upstream hydrocarbons, midstream infrastructure, or adjacent sectors — Curtis offers the combination of sanctions expertise and sector-specific transactional experience required to move from analysis to execution.

About Curtis

Curtis, Mallet-Prevost, Colt & Mosle LLP is an international law firm with offices across the Americas, Europe, the Middle East, and Central Asia. The firm's Latin America practice advises private companies, financial institutions, project developers, and fund managers on complex cross-border transactions, regulatory matters, and disputes across the region.