This bill bars United States persons from engaging in petroleum-related transactions with Venezuela that were permitted under the October 2023 Partial Agreement (the Barbados Agreement) or under OFAC General License No. 41 or No. 8M as of the day before enactment. The prohibition takes effect on enactment and remains until the President certifies that the Maduro regime has recognized the July 28, 2024, electoral victory of Edmundo Gonzalez and relinquished power or a transitional government acceptable to the legitimately elected opposition is in place.
The measure directs the Treasury Secretary (in consultation with State) to implement the ban using authorities under the International Emergency Economic Powers Act, makes violations subject to IEEPA penalties, and gives the President a narrow national-security waiver that must be reported to specified congressional committees. The bill directly affects U.S. energy firms, financial institutions, and anyone operating under the now-covered licenses or agreements, and it creates administrative and legal questions about license rescission, contract continuity, and enforcement of secondary exposures abroad.
At a Glance
What It Does
Statutorily prohibits petroleum-related transactions by U.S. persons that were permitted under the Barbados Agreement or under OFAC General License No. 41 or No. 8M as of the day before enactment. It authorizes the Treasury Secretary, with State consultation, to issue implementing regulations and to use IEEPA authorities to enforce the ban.
Who It Affects
U.S. oil and gas companies, investors and lenders with exposure to Venezuelan petroleum projects, financial intermediaries that clear or finance related transactions, and entities operating under OFAC General Licenses 41 and 8M. It also affects Venezuelan opposition actors by designating leverage tied to electoral recognition.
Why It Matters
This bill reverses or freezes certain transactional openings created by diplomatic agreements and OFAC licensing, making congressional policy a statutory condition on investment tied to electoral outcomes. It raises enforcement, licensing, and extraterritorial exposure questions that could disrupt contracts, financing, and project timelines in the Venezuelan energy sector.
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What This Bill Actually Does
The bill creates an immediate, statutory prohibition on a defined category of energy-related economic activity between United States persons and Venezuela. Specifically, it pulls back access that had been permitted as a result of the October 2023 Partial Agreement (the Barbados Agreement) and any petroleum transactions authorized under OFAC General License No. 41 or No. 8M as of the day before the bill’s enactment.
The ban is forward-looking from enactment and is stated as a condition tied to respect for the July 28, 2024, election results.
To implement the prohibition, the Secretary of the Treasury—working with the Secretary of State—may issue regulations and exercise the President’s delegated IEEPA powers. The bill ties enforcement to the penalties available under IEEPA section 206(b) and (c), so civil and criminal sanctions used for other sanctions programs apply to violations.
It also requires all federal agencies to take appropriate measures within their authorities to carry out the statute.The President retains a national-security waiver: the executive may exempt the prohibitions if the President determines a waiver is in the national security interest and submits a written report to the named congressional committees (with a possible classified annex). The statutory prohibition terminates only when the President certifies to Congress that the Maduro regime has recognized Edmundo Gonzalez’s victory and either transferred power or allowed a transitional government that includes the legitimately elected opposition.The bill defines relevant terms narrowly for operational purposes: 'United States person' includes U.S. citizens, lawful permanent residents, entities organized under U.S. law (including their foreign branches), and any person physically present in the United States.
It also identifies the congressional committees to receive waiver reports and clarifies that Treasury will rely on IEEPA authorities to fill regulatory gaps, which signals aggressive administrative enforcement rather than relying solely on diplomatic or executive orders.
The Five Things You Need to Know
The prohibition expressly covers petroleum-related transactions allowed by the October 2023 Barbados Agreement and any petroleum transactions authorized under OFAC General License No. 41 or General License No. 8M as of the day before enactment.
The ban takes effect on the date of enactment and remains in place until the President certifies that the Maduro regime has recognized the July 28, 2024, electoral victory of Edmundo Gonzalez and relinquished power or a transitional government acceptable to the legitimately elected opposition exists.
The Secretary of the Treasury, in consultation with the Secretary of State, may issue regulations and may exercise authorities provided under IEEPA sections 203 and 205 to implement the statute.
A person who violates the prohibition or related implementing rules is subject to the civil and criminal penalties set out in IEEPA section 206(b) and (c).
The President may waive the ban on national security grounds but must submit a written report (which may include a classified annex) explaining the determination to the specified Senate and House committees.
Section-by-Section Breakdown
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Short title
Gives the act its formal name: the 'Halt All United States Investments in Venezuela’s Energy Sector Act of 2025.' This is purely captioning but signals that the statutory focus is on investment flows into Venezuela’s energy sector rather than a broader trade or visa regime.
Findings supporting the policy
Sets out Congress’s rationale: it recounts the July 28, 2024, election results, alleges a refusal by the Maduro regime to respect those results, and cites post-election repression. While findings carry no operative legal effect, they frame the statute’s political and human-rights rationale and will matter for interpretive disputes about congressional intent if enforcement or litigation follows.
Prohibition on specified petroleum-related transactions
Imposes the core ban: starting on enactment, any petroleum-related transaction that was allowed as a result of the Barbados Agreement or that relies on a license issued after that agreement is prohibited for United States persons. The text also pulls in transactions permitted under OFAC General License No. 41 and No. 8M as of the day before enactment. Practically, that means previously permitted activities under those diplomatic and licensing vehicles are statutorily blocked and will require Treasury rulemaking or licenses to re-authorize.
Waiver, implementation authority, and penalties
Section 3(b) gives the President a national-security waiver but conditions it on a written report to the named congressional committees. Section 3(c) vests implementation authority in the Treasury Secretary (consulting State) and explicit authority to use IEEPA sections 203 and 205, indicating Treasury can issue broad regulations and licensing rules. Violations are tied to the civil and criminal penalties set out in IEEPA section 206(b)–(c), aligning enforcement with other U.S. economic sanction regimes and signaling potential severe consequences for noncompliance.
Agency duties, termination trigger, and definitions
Requires all U.S. agencies to take appropriate measures within their authority to effectuate the statute, creating an interagency obligation. The ban ends only upon a presidential determination that Maduro has recognized Gonzalez’s victory and relinquished power or a transitional government acceptable to the legitimately elected opposition exists. The section also defines 'United States person' (including entities organized under U.S. law and persons physically in the U.S.) and specifies the congressional committees that receive waiver reports, which matters for oversight and classified reporting.
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Explore Foreign Affairs in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Venezuelan opposition and supporters: The statute converts U.S. investment leverage into a formal, statutory tool designed to increase economic pressure on the Maduro regime until electoral recognition occurs.
- U.S. policymakers and democracy-focused NGOs: Gains a clear legislative instrument to signal U.S. priorities on democratic outcomes and human-rights enforcement in Venezuela, strengthening a policy toolkit for advocacy and oversight.
- Treasury and sanctions enforcers: The bill expands statutory authority for Treasury to regulate and enforce in this policy area, giving OFAC clearer statutory footing for rescinding previously issued transactional permissions tied to the Barbados Agreement.
Who Bears the Cost
- U.S. energy companies and investors with Venezuelan exposure: Firms that signed contracts, joint ventures, or financing arrangements under the Barbados Agreement or OFAC licenses face lost revenue, stranded investments, or abrupt contractual risk.
- Financial institutions and intermediaries: Banks, insurers, and capital providers that clear, finance, or insure petroleum-related flows to Venezuela will need to revise compliance programs to avoid IEEPA penalties and to screen for transactions tied to covered activities.
- U.S. federal agencies (implementation burden): Treasury, State, and other agencies will need to draft regulations, issue licensing guidance, and manage legal challenges and enforcement, imposing resource and coordination costs.
- Venezuelan energy-sector workers and local contractors: A sudden halt to U.S.-backed projects can reduce employment and service contracts in-country, shifting economic risk onto local workforces and suppliers.
- Allied governments and private partners: Countries and companies that coordinated around the Barbados Agreement may face diplomatic frictions or uneven enforcement expectations if U.S. statutory policy diverges from multilateral approaches.
Key Issues
The Core Tension
The central dilemma is the trade-off between exerting immediate economic pressure to enforce democratic outcomes and the collateral costs of doing so: disrupting legitimate, licensed commercial activity and creating legal and market uncertainty for U.S. firms and foreign partners. The bill solves the first problem by making a hard statutory cut-off tied to electoral recognition, but it relies on broad executive discretion, imposing potential economic harm and administrative burdens that could undercut the policy’s longer-term effectiveness.
The bill creates several implementation and legal puzzles. First, it singles out 'petroleum-related transactions' tied to the Barbados Agreement and two named OFAC general licenses without defining the boundaries of 'petroleum-related'—leaving room for disputes over supporting services, upstream vs. downstream activities, and ancillary financing.
Second, rescinding or overriding previously issued OFAC licensing (GL41/8M) raises questions about grandfathering for contracts executed in reliance on those licenses and potential takings or breach-of-contract claims in international arbitration.
Enforcement will also be administratively heavy. Treasury must translate a policy judgment into precise regulations and compliance guidance, determine how to treat foreign affiliates and foreign-incorporated counterparties, and police secondary exposures where non-U.S. entities continue activity with Venezuela.
The national-security waiver and the termination trigger rest on presidential determinations, which centralize discretion in the executive branch and invite legal and political disputes over timing, evidence, and the acceptable composition of a 'transitional government' referenced in the termination language. Finally, the extraterritorial reach—by covering foreign branches of U.S. entities—could complicate relations with allies and counterpart firms, especially where multilateral coordination around sanctions and licenses had previously been the norm.
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