U.S. "Resource Capture" in Venezuela: AML Risks from Shielded Oil Proceeds in a Geopolitical Grey Zone

This news update is what one nation calls "resource management and another may label it criminal proceeds.  This story is not about "money laundering" per se under U.S. law, but it underscores, globally, how geopolitical actions can create AML grey zones.   

Executive Summary

• In early January 2026, the United States executed a rapid military and economic operation in Venezuela, capturing President Nicolás Maduro and seizing control of the country's oil revenues.
• Through a series of actions, including a January 3 military raid, a January 6 announcement of U.S. oversight of oil sales, a January 9 Executive Order shielding proceeds from creditors, and the first $500 million sale on January 14, the U.S. has directly marketed Venezuelan crude and deposited funds in U.S.-controlled accounts in Qatar.
• This unprecedented move bypasses Venezuela's $150–170 billion in external debts and international legal norms, with revenues held in third-country accounts to avoid seizure by creditors.
• While framed by the U.S. as a stabilising "historic energy deal," critics view it as a violation of sovereignty, raising questions about the legitimacy of the underlying actions.

For the global AML community, this creates significant compliance challenges.

• The single criminality test in many jurisdictions means that even if the proceeds are "legal" under U.S. law, they may be treated as criminal if your country would criminalise similar conduct (e.g., expropriation, aggression, or plunder).
• Funds flowing through international banks, especially via Qatar, could trigger red flags for laundering, sanctions circumvention, or exposure to politically exposed persons.
• Key risks include secondary transactions, cross-border flows, and unusual routing.
• Compliance teams should implement enhanced due diligence, monitor for Venezuela-related keywords, align with local criminality standards, and file reports where suspicion arises.
• This case highlights how geopolitical interventions can generate AML grey zones, underscoring the need for vigilance, documentation, and legal consultation.

Background: Overview of U.S. Actions in Venezuela

• In early January 2026,
• The U.S. executed a bold military and economic strategy in Venezuela following years of sanctions and tensions under the Maduro regime.
• On January 3,
• U.S. Special Forces captured President Nicolás Maduro and his wife, Cilia Flores, in Caracas during a raid that included strikes on military sites.
• Maduro, indicted on U.S. narco-terrorism charges, was extradited to New York. This operation ended Maduro's 13-year rule and installed Vice President Delcy Rodríguez as acting president, who has cooperated with U.S. demands.
• Seizing the moment, the Trump administration moved to control Venezuela's vast oil reserves, the world's largest at over 300 billion barrels, but was crippled by sanctions, mismanagement, and debt.
• On January 6,
• The U.S. Department of Energy announced a deal to acquire 30–50 million barrels of stranded Venezuelan crude (valued at $2–3 billion), with the U.S. marketing, selling, and distributing proceeds.
• This includes authorising U.S. imports of Venezuelan oil equipment and selectively lifting sanctions.
• On January 9, A key enabler was the Executive Order, which shields revenues from Venezuela's $150–170 billion in debts (owed to bondholders, oil firms like Exxon and ConocoPhillips, China, and others).
• Funds are held in U.S.-controlled accounts at "globally recognised banks," exempt from seizures or claims.
• The first sale on January 14 netted $500 million, with proceeds deposited in Qatar, a U.S. ally seen as neutral to avoid litigation risks.
• Additional sales are expected, prioritising U.S. manufacturers for imports and Venezuelan infrastructure/healthcare needs.
• This approach marks a shift:
• Unlike past interventions (e.g., Iraq's post-2003 contracts under local law), the U.S. is directly handling sales and funds, bypassing courts and international arbitration.
• Trump has pitched it as a "historic energy deal" benefiting both nations, but critics (e.g., China, EU) decry it as a sovereignty violation.
• Oil executives, invited to a White House meeting, were cautious; Exxon CEO Darren Woods called Venezuela "uninvestible" without reforms, prompting Trump to threaten to exclude it.
• Rump's strategy appears to aim for energy dominance, lower global prices, and Venezuelan stability, but raises legal and ethical questions amid ongoing U.S. oversight.

AML Compliance Implications: Key Risks and Recommendations

• For AML professionals worldwide, whether in financial institutions, regulatory bodies, or compliance roles, this U.S.-Venezuela oil deal presents unique challenges in risk assessment, due diligence, and enforcement.
• The arrangement involves U.S.-controlled funds from Venezuelan oil sales held in third-country accounts (e.g., Qatar), shielded by a U.S. Executive Order from creditor claims. While the U.S. frames this as legitimate foreign policy to stabilise Venezuela and benefit its people, other jurisdictions may view the underlying actions (military capture, asset seizure, and revenue redirection) differently, triggering AML red flags.
• A core consideration is the single criminality test embedded in many AML regimes (e.g., under FATF standards, EU directives, or national laws like Jersey’s Proceeds of Crime Law, the UK's Proceeds of Crime Act or Australia's AML/CTF Act).
• This principle evaluates predicate offences based on the laundering jurisdiction's laws, not the origins.
• It doesn't matter whether the oil seizure and sales are "legal" under U.S. law or Venezuelan interim agreements;
• The key question is whether your jurisdiction would criminalise similar conduct.
• For instance:
• If a country deems the U.S. actions as theft, expropriation without due process, or violation of international law (e.g., UN Charter prohibitions on force), handling related proceeds could constitute money laundering. Critics, including legal experts from Chatham House and Brookings, argue that the Maduro capture and oil takeover lack a clear international justification, potentially equating to "aggression" or "plunder" under some frameworks.
• Proceeds flowing through global banks (e.g., via Qatar, a hub for energy finance) could enter supply chains, investments, or payments. AML teams must screen for exposure: Are funds traceable to these sales? Do they involve sanctioned entities (e.g., PDVSA remnants) or politically exposed persons (e.g., Venezuelan officials)?
• Risk scenarios include: (1) Secondary transactions (e.g., U.S.-approved imports funding Venezuelan banks or firms); (2) Cross-border flows to creditors or partners; (3) Potential circumvention of sanctions if funds indirectly benefit restricted parties.

Practical Recommendations:

• Enhanced Due Diligence (EDD):
• For any Venezuela-related transactions, verify fund origins against U.S. EO details and OFAC guidance.
• Use tools like transaction monitoring for keywords (e.g., "Venezuelan crude," "Qatar account").
• Jurisdictional Alignment:
• In dual-criminality jurisdictions (e.g., U.S. ML laws require foreign predicates to be crimes here too), this may pose fewer issues.
• But in single-criminality ones (e.g., JERSEY and many EU states), consult local FIUs or regulators, e.g., could this mirror "corruption" or "embezzlement" predicates?
• Reporting Obligations:
• If suspicion arises (e.g., funds appear "laundered" via neutral venues to evade claims), file SARs/STRs promptly.
• Watch for red flags such as unusual routing through Qatar or links to high-risk sectors (e.g., energy, sovereign funds).
• Global Coordination:
• Engage with FATF or regional bodies; this could prompt updated risk assessments for "state-sponsored" asset flows.
• For firms in Qatar or Gulf states, align with local AML laws while noting U.S. extraterritorial reach (e.g., via secondary sanctions).
• Mitigation Strategies:
• Advise clients to seek U.S. licenses for dealings. Monitor for litigation creditors who may challenge the EO in international forums, creating compliance pivots.

Conclusion

• This isn't "money laundering" per se under U.S. law, but globally, it underscores how geopolitical actions can create AML grey zones.
• What one nation calls "resource management," another may label criminal proceeds: Prioritise documentation and legal opinions to navigate potential exposures.
• Stay vigilant:

Thank you to Ben Shenton for highlighting this story:-

https://www.linkedin.com/posts/ben-shenton-88643120_the-us-just-sold-500-million-of-venezuelan-activity-7418580256598433793-4-Ti?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAA_6EIB0wPAWyjQcuq_XiD3asUV8xpMeZ0