Sanctions GateDecember 15, 2025

    Chevron's GL41: The Template for Venezuela Oil Access

    How the US oil major maintained operations in Venezuela—and what it means for other companies.


    What Changed

    Trump has indicated US oil companies should enter Venezuela to exploit its 303 billion barrel reserves. GL41 expansion or new licenses likely under discussion.

    Why It Matters

    Chevron's license proves the mechanics of sanctions-compliant Venezuela operations. Any recovery scenario depends on similar authorizations for broader investment.

    Analysis

    General License 41 (GL41) authorizes Chevron Corporation to conduct limited operations in Venezuela despite comprehensive sanctions. It serves as the template for how US companies might re-engage with Venezuelan oil under a new political dispensation.

    Background

    Chevron has operated in Venezuela since the 1920s and maintained a presence even after sanctions intensified. When the Trump administration imposed maximum pressure sanctions in 2019, Chevron received specific authorization to continue limited activities.

    GL41 Provisions

    The license authorizes Chevron and its subsidiaries to:

    Maintain existing joint ventures with PDVSA

    Continue essential operations at existing facilities

    Export Venezuelan crude oil to the United States

    Conduct necessary financial transactions with PDVSA

    The license is automatically renewed monthly and has been maintained by both Trump and Biden administrations.

    Operational Scope

    Under GL41, Chevron operates four joint ventures in Venezuela:

    Petropiar (Orinoco Belt)

    Petroboscán

    Petroindependencia

    Petroindependiente

    These ventures produce approximately 200,000 barrels per day of crude oil—a significant portion of Venezuela's current output.

    Revenue Model

    Crucially, GL41 allows Chevron to collect on approximately $3 billion in debts owed by PDVSA through oil deliveries. Rather than making cash payments, PDVSA delivers crude to Chevron, which markets it and credits the deliveries against outstanding receivables.

    This "oil-for-debt" mechanism could serve as a model for creditor recovery in a broader restructuring.

    Implications for Restructuring

    GL41 demonstrates that:

    1. OFAC will issue specific licenses for commercially important operations

    2. Oil-linked payment mechanisms are acceptable to US regulators

    3. Continued engagement is possible despite comprehensive sanctions

    If the Rodriguez government engages constructively, expanded versions of GL41-style licenses could enable broader oil sector investment—the key driver of any recovery scenario.

    Constraint Snapshot

    Authority

    License applies to Chevron specifically

    Creditor Leverage

    Demonstrates oil-for-debt mechanism works

    Enforcement

    Not directly applicable to judgment creditors

    Sanctions

    Template for future expanded authorizations

    Watchlist

    • Other oil company license applications
    • GL41 scope expansion discussions
    • Rodriguez government oil policy
    • Congressional oversight of license policy

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