The Energy Workforce & Technology Council recently convened a discussion between member companies and officials from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) to address sanctions compliance challenges affecting energy service companies operating internationally, with a particular focus on Venezuela and emerging risks in Mexico.
EWTC members participated in the conversation, sharing perspectives on how current sanctions policies and licensing requirements impact day-to-day operations, project planning, and global supply chains. Much of the discussion centered on OFAC’s Venezuela-related general licenses and the practical questions companies face when interpreting and implementing them.
Industry participants raised concerns about how the licenses apply to U.S. companies and their international subsidiaries, noting that complex corporate structures can create uncertainty about whether entities are eligible to rely on specific authorizations. Companies also discussed operational challenges related to transaction reporting requirements and the hesitancy among financial institutions to process payments tied to Venezuelan activities, even when those transactions fall within authorized parameters.
Another key topic was the coordination between OFAC and the Department of Commerce’s Bureau of Industry and Security (BIS) on licensing for dual-use goods and technologies. Energy service providers noted that critical equipment—such as valves and other specialized components—may require multiple layers of regulatory approval, and they emphasized the importance of clear guidance and efficient processing to avoid delays that could affect operations.
Beyond Venezuela, the conversation also addressed increasing risks related to cartel activity in Mexico’s energy sector. Participants discussed how organized criminal groups have expanded into fuel theft, smuggling, and other activities that can intersect with legitimate energy operations. Companies highlighted the challenges of conducting due diligence on third parties and identifying indirect connections to illicit actors, underscoring the need for practical compliance guidance and clear risk indicators. OFAC officials welcomed the industry’s feedback and reaffirmed their commitment to maintaining open lines of communication with industry stakeholders as companies navigate evolving sanctions requirements. The Council will continue working with member companies to support ongoing dialogue with federal agencies to ensure U.S. energy service providers have the clarity and tools needed to operate responsibly while maintaining full compliance with U.S. sanctions policy.
If you are interested in joining the working group on Venezuela or have additional questions, please reach out to jsantos@energyworkforce.org
Jessica Santos, Director Government Affairs, writes about industry-specific policies for the Energy Workforce & Technology Council. Click here to subscribe to the Energy Workforce newsletter, which highlights sector-specific issues, best practices, activities and more.
