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Financial infrastructure / payment rails

Money needs a pipeline too

An energy system is incomplete if money cannot move legally, verifiably, and predictably between the parties—even when the gas, turbines, and buyers are already there.

When we think about energy infrastructure, we usually assume a basic set of components: the field, the pipeline, the processing, the plant, the substation.

But in Venezuela there's another stretch missing: the contracts, the banks, the payments, the settlement arrangements.

You can have gas, turbines and buyers. You can even have an economically attractive project. But if money can't move in a legal, verifiable and reasonably predictable way between the parties, the system is literally incomplete.

A lot of what's happening in Venezuela gets described as “a change in sanctions.” I see it more as the gradual reconstruction of a financial infrastructure to operate in. And honestly, it's still far from being a normal one.

The payment rail is infrastructure

OFAC authorizes oil and gas operations for companies like BP, Chevron, Eni, Maurel & Prom, Repsol and Shell under General License 50B. But the license doesn't simply say “you can invest now.” It defines a contractual architecture: agreements with Venezuela's interim government, PDVSA or PDVSA-controlled entities must be governed under U.S. jurisdiction. Dispute resolution must happen in the United States, the United Kingdom, France or Singapore. Certain payments must flow into the Foreign Government Deposit Funds or another account designated by Treasury. And OFAC requires reporting on parties, amounts, values, dates and payments made to the Venezuelan government, first when transactions begin and then every 90 days.

That's not an administrative detail. That's infrastructure.

Gas can travel through a pipeline designed by BP or Shell. But money has a route too. It needs jurisdiction, permitted accounts, conditions, reporting, and clearly defined entities that can touch it and others that can't. In that sense, the payment rail is literally another pipeline. It just doesn't show up on the map.

Signing is not executing

There's another detail worth paying attention to. General License 49A allows companies to negotiate and sign contingent contracts for new investments in oil, gas, petrochemicals and electricity. But signing is not the same as executing. Execution requires a separate authorization from OFAC.

You can have an interested company, negotiate the EPC, pick the land, structure the buyer and even sign. And still have a gap between a project that's commercially ready and one that can legally begin to execute. That's a real constraint. Not an engineering one. A financial and legal architecture one.

When the financial circuit breaks

The Perla project is the clearest warning of what happens when that architecture breaks down.

Eni and Repsol kept producing gas for Venezuela's domestic market while the crude payment mechanism was interrupted by changes in U.S. authorizations. The debt kept accumulating until it reached around $3.3 billion. In 2026, Eni was able to lift Venezuelan oil again as payment in kind under the new framework.

The plant didn't blow up. The field didn't disappear. What broke was the financial circuit. And when that happens long enough, it eventually becomes a physical problem too: maintenance stops getting funded, suppliers stop getting paid, spare parts stop coming in, new investments stop being justified.

That's exactly what Venezuela should avoid repeating.

So when I hear proposals about private generation or new infrastructure around oil assets, my first question is no longer just where the fuel comes from. I also want to know who pays for it, at what rate, into which account, who measures the volume delivered, what happens if a license changes, and where a dispute gets resolved.

And specifically for power infrastructure, the real question is whether the local buyer can become a reliable enough counterparty for someone to finance the asset over twenty years. That point is probably going to separate a lot of real projects from a lot of nice presentations.

A serious Venezuelan energy project probably needs to think from the start about verifiable metering, independent auditing, contracts with measurable obligations, escrow mechanisms, payment waterfalls, protections against non-payment, sanctions-change clauses and dispute jurisdiction. Not because OFAC requires all of that. But because the goal isn't simply to get an operator in. The real goal is to keep it operating through fifteen years of political, regulatory and financial change. And that should be a non-negotiable requirement.

Investability is the alignment of several layers

Investability shows up when several layers align at the same time: the physical asset, the contract, the buyer, legal protection, the bank and the payment rail. Maybe that's why certain pieces of Venezuela can move forward before the country as a whole does. You don't need to fix the entire financial system. You need to build a tight enough, verifiable and reliable circuit around a specific asset.

For years we thought about Venezuelan infrastructure in terms of things you could see: plants, substations, refineries, pipelines, ports. But a meaningful part of the reconstruction will probably happen in systems that aren't visible.

In the end, a pipeline only works if something can flow from one end to the other. The same applies to money.

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