U.S.–Venezuela Oil Deal: Control, Ownership and Sovereignty Under International Law
- Edmarverson A. Santos
- 5 hours ago
- 33 min read
Introduction
The US-Venezuela oil deal announced in late August 2026 does not, on the information presently available, establish that the United States has acquired ownership of Venezuela’s petroleum reserves or sovereignty over its natural resources. President Donald Trump described the arrangement as giving the United States “majority control” over more than 65 billion barrels of proven reserves. Venezuelan interim President Delcy Rodríguez later described a 25-year energy project involving 17 strategic oilfields, eight new greenfield blocks, and an initial production objective above 1.5 million barrels per day, while maintaining that Venezuela retains ownership and sovereignty over its natural resources (Reuters, 2026).
The apparent tension between those statements is largely a question of legal characterization. Control over petroleum production, management, purchasing rights, corporate governance, or economic output is not the same as ownership of the reserves themselves. Nor does extensive commercial participation by foreign entities necessarily amount to a transfer of sovereign authority over the territory or natural resources of the host state.
Reports concerning a 55 percent effective U.S. output position and rights extending for up to 100 years illustrate the distinction. Those terms, if confirmed in the operative agreements, could create substantial economic and operational rights. They would not by themselves demonstrate that Venezuela had transferred title to its petroleum deposits or surrendered sovereignty over them. Their precise legal effect remains uncertain because the relevant interstate and commercial instruments have not been made public (Associated Press, 2026).
International law permits states to authorize foreign participation in the exploitation of natural resources while retaining sovereign authority over those resources. UN General Assembly Resolution 1803 (XVII) recognizes permanent sovereignty over natural wealth and resources and contemplates foreign investment and agreed participation in their development, provided that such arrangements respect the sovereignty of the state concerned (UN General Assembly, 1962). The International Court of Justice has also recognized the principle of permanent sovereignty over natural resources as part of customary international law (ICJ, 2005).
Venezuelan constitutional law reinforces the distinction between state ownership and commercial exploitation. Article 12 of the Constitution provides that mineral and hydrocarbon deposits existing within Venezuelan territory and relevant maritime areas belong to the Republic, form part of the public domain, and are inalienable and imprescriptible (Constitution of Venezuela, 1999). That rule concerns ownership of the deposits themselves; it does not, without further legal analysis, answer what contractual, operating, production, or investment rights may lawfully be granted to foreign participants.
The legal consequences of the arrangement will ultimately depend on the instruments through which the reported U.S. control is exercised. An interstate agreement governed by international law, a petroleum concession, a corporate joint venture, an operating license, and a contractual right to purchase production create different rights and obligations. Until the governing documents are disclosed, claims that the United States now owns Venezuelan oil, that Venezuela has transferred sovereignty over its reserves, or that the arrangement is legally invalid remain premature.
1. What the US Venezuela Oil Deal Actually Does
The public description of the U.S.–Venezuela arrangement combines several different categories of rights under the broad language of an “oil deal.” Some terms have been stated publicly by Venezuelan officials, while others have emerged through U.S. statements or reporting based on unnamed officials. The operative interstate documents, corporate instruments, and field-level petroleum contracts have not been released.
The available record supports the existence of an announced 25-year bilateral energy project centered on major Venezuelan oilfields and expanded production. It also records a U.S. claim to “majority control” over more than 65 billion barrels of Venezuelan oil reserves. What remains unclear is the legal mechanism through which that control would be exercised.
1.1 The 25-Year Bilateral Project
Delcy Rodríguez described the arrangement as a 25-year bilateral project involving Venezuela and the United States. According to her public account, it covers 17 strategic oilfields and seeks an initial production level above 1.5 million barrels per day. She also referred to eight additional greenfield blocks intended for new development (Reuters, 2026).
The 1.5 million-barrel figure is an initial production objective rather than a guarantee of future output. Venezuela was producing approximately 1.25 million barrels per day when the arrangement was announced, following years of infrastructure deterioration, investment constraints, sanctions, and operational difficulties (Reuters, 2026).
The 25-year duration is legally notable because the reformed Organic Hydrocarbons Law also sets a maximum initial term of 25 years for mixed enterprises carrying out primary hydrocarbons activities, with a possible extension of up to 15 years (Venezuela, 2026, art. 35). That numerical correspondence does not establish that the announced bilateral project is itself an Article 35 mixed enterprise.
Nor do the announced fields and production targets reveal the project’s juridical structure. Current Venezuelan law permits several routes for petroleum development, including mixed enterprises and contractual arrangements involving private operators. The available information does not yet establish which statutory mechanism, or combination of mechanisms, is being used.
1.2 The 65-Billion-Barrel Control Claim
Trump stated that the arrangement would give the United States “majority control” over more than 65 billion barrels of Venezuela’s proven oil reserves through a partnership with private business (Reuters, 2026). The scale of the figure is politically significant, but the term “control” does not determine the legal ownership of the petroleum.
Proved reserves are a petroleum-resource classification. They refer to quantities that geological and engineering information indicates can be recovered with reasonable certainty from known reservoirs under existing economic and operating conditions (U.S. Energy Information Administration, n.d.). A reserves estimate measures recoverable petroleum; it does not allocate title to the deposits.
Control may also take several forms. It can arise through corporate voting power, operating authority, rights to production, purchasing arrangements, management powers, or other contractual mechanisms. None of those forms necessarily constitutes ownership of the underlying hydrocarbon deposit.
Venezuelan constitutional law makes that distinction clear. Article 12 provides that hydrocarbon deposits within Venezuelan territory, beneath the territorial sea, within the exclusive economic zone, and on the continental shelf belong to the Republic. They form part of the public domain and are inalienable and imprescriptible (Constitution of Venezuela, 1999, art. 12).
The 2026 Organic Hydrocarbons Law preserves this rule even when private operators conduct primary petroleum activities. Article 40 expressly states that the Republic retains ownership of the hydrocarbon deposits affected by such operations (Venezuela, 2026, art. 40).
Trump’s language of “majority control” cannot, on the evidence presently available, be treated as proof that ownership of 65 billion barrels has passed to the United States. It describes a claimed economic or operational position whose precise legal content depends on documents that remain unavailable.
1.3 The 55% and 100-Year Terms
The Associated Press reported additional commercial terms attributed to a U.S. official who spoke on condition of anonymity. According to that account, a new company would receive rights over specified oilfields for 100 years, while the United States would receive 55 percent of the company’s “effective output.” AP reported that this position would include some form of ownership interest together with rights to purchase petroleum at cost, but the precise division between those elements was not disclosed (Associated Press, 2026).
These reported terms do not establish ownership of 55 percent of Venezuela’s oil reserves. A corporate interest, an entitlement to production, and a right to purchase crude are legally distinct. Each may provide substantial economic access to petroleum produced under the arrangement without transferring title to the underlying deposits.
The reported 100-year period must be treated with similar caution. It appears to concern rights associated with particular fields or a commercial structure, rather than the publicly announced duration of the broader bilateral project. Different layers of the same transaction can lawfully carry different terms.
The absence of the operative documents prevents a definitive characterization. It is not yet possible to determine whether the 100-year figure refers to a concession, contractual operating right, corporate entitlement, renewable authorization, or another form of petroleum right. The same uncertainty applies to the legal composition of the reported 55 percent position.
2. Control, Ownership and Sovereignty Are Different Rights
The legal analysis depends on three concepts that political descriptions often blur. Ownership concerns legal title to property or assets. Control may arise from contracts, corporate governance, operating authority, production entitlements, or purchasing rights. Sovereignty concerns the public authority of the state over its territory and natural resources.
A foreign company may obtain extensive economic and operational rights within a petroleum project without acquiring sovereignty over the territory in which the oil is located. It may also acquire rights over extracted petroleum without becoming owner of the geological deposit from which the petroleum was produced.
Venezuelan law now draws these distinctions expressly. Private operators may conduct primary activities, receive production-based remuneration, use operational areas and assets, and in some circumstances commercialize petroleum directly. The Republic nevertheless retains ownership of the deposits and its sovereign authority over the resource base (Venezuela, 2026, arts. 40–42, 68).
2.1 Petroleum in Situ and Sovereign Title
Petroleum in situ is petroleum that remains within the geological deposit. Under Venezuelan constitutional law, those deposits belong to the Republic. Article 12 does more than establish regulatory jurisdiction: it classifies hydrocarbon deposits as public-domain property and makes them inalienable and imprescriptible (Constitution of Venezuela, 1999, art. 12).
This rule of domestic property law operates alongside Venezuela’s sovereign authority over natural resources located within its territory and maritime zones. The concepts are related but distinct. State ownership describes who holds title to the deposit under Venezuelan law. Permanent sovereignty over natural resources concerns the international legal authority of a state to determine how its natural wealth is explored, developed, and disposed of.
Foreign participation does not require a transfer of the deposit itself. A petroleum operator can receive authority to explore, drill, extract, manage facilities, or market production while the reservoir remains legally vested in the Republic.
The 2026 law preserves that structure. Under Article 40, private operators may conduct primary activities under qualifying contractual arrangements while the Republic retains ownership of the hydrocarbon deposits. Article 42 separately allows temporary rights over operational areas, assets, and materials, which terminate when the contract ends (Venezuela, 2026, arts. 40, 42).
A right to enter an area and extract oil is thus not the same as a conveyance of the geological deposit. Operational authority does not amount to territorial sovereignty, and a long contractual duration does not by itself change the constitutional ownership of the resource.
2.2 Production Rights After Extraction
Extraction creates a different stage in the legal relationship. Once petroleum has been produced and officially measured, an operator may acquire contractual rights to specified volumes, revenues, or marketing opportunities without acquiring title to the reservoir from which the petroleum originated.
The 2026 reform expressly permits this structure. Article 41 allows remuneration for qualifying private operators to consist of a percentage of officially measured petroleum volumes. Those volumes may, subject to the statutory conditions, be marketed directly by the operator after applicable state obligations have been satisfied (Venezuela, 2026, art. 41).
Article 68 also permits the competent ministry to authorize mixed enterprises and qualifying private operators to commercialize all or part of the natural hydrocarbons produced in an assigned area. The provision states that such authorization does not transfer title to the deposits and does not permit security interests over the deposits or sovereign rights (Venezuela, 2026, art. 68).
This distinction is central to the reported U.S. position. Rights over produced barrels can be economically extensive and may include production shares, direct commercialization, or purchasing rights. Petroleum remaining underground continues to fall within a separate proprietary and sovereign framework.
2.3 Corporate Control Without Sovereign Ownership
Corporate control can also exist independently of sovereign ownership. A shareholder may influence appointments, budgets, investment decisions, financing, production strategy, or commercial policy. Contractual provisions can create comparable influence through management rights, operating authority, purchasing arrangements, or control over specified revenue streams.
The reported 55 percent effective-output position could accordingly provide U.S. interests with substantial economic access to production under the arrangement. It does not establish a 55 percent ownership interest in Venezuela’s petroleum reserves, nor does the available reporting establish that U.S. interests control 55 percent of the equity or voting rights of the relevant company.
Venezuelan petroleum law expressly permits significant private operational authority while retaining the deposits in public ownership. Article 40 allows qualifying private companies to assume integrated management of primary activities at their own cost and risk. Article 41 permits production-based remuneration, and Article 42 permits temporary use of operational areas and assets. The Republic nevertheless retains title to the deposits (Venezuela, 2026).
The American and Venezuelan descriptions are consequently not necessarily inconsistent. Extensive U.S. economic or operational control could coexist with Venezuelan ownership of the deposits and continued sovereign authority over the resource base. Whether the announced arrangement actually creates that structure can be determined only from the legal instruments governing it.
3. Permanent Sovereignty Over Natural Resources
The principal international-law concept governing the sovereignty dimension is permanent sovereignty over natural resources. The doctrine developed during decolonization and debates over economic self-determination, foreign investment, nationalization, and the ability of states to control resources located within their territory.
Permanent sovereignty is not a prohibition on foreign investment. It does not require natural resources to be developed exclusively by state enterprises. Its central premise is that decisions concerning the exploration, development, and disposition of natural wealth remain subject to the sovereign authority of the state.
3.1 Resolution 1803 and Resource Sovereignty
UN General Assembly Resolution 1803 (XVII), adopted in 1962, remains the classic formulation of permanent sovereignty over natural resources. It recognizes the right of “peoples and nations” to permanent sovereignty over their natural wealth and resources and connects the exercise of that right with national development and the well-being of the population (UN General Assembly, 1962).
The resolution expressly contemplates foreign capital. Paragraph 2 addresses exploration, development, and disposition of natural resources, together with the admission of foreign investment under conditions considered necessary or desirable. Paragraph 3 provides that foreign capital and its earnings are governed by agreed terms, national law, and international law, with profits shared in proportions freely agreed between investors and recipient states.
Paragraph 3 also states that foreign participation must not impair the sovereignty of the state over its natural wealth and resources (UN General Assembly, 1962). Paragraph 8 adds that foreign investment agreements freely entered into by or between sovereign states are to be observed in good faith.
Resolution 1803 is a General Assembly resolution rather than a treaty, and its individual provisions do not acquire binding treaty status merely through adoption by the Assembly. The broader principle of permanent sovereignty over natural resources, however, has been recognized beyond the resolution itself.
In Armed Activities on the Territory of the Congo, the International Court of Justice described permanent sovereignty over natural resources as a principle of customary international law (ICJ, 2005, para. 244). That recognition gives the principle an international legal significance distinct from the formal status of Resolution 1803.
The doctrine permits Venezuela to authorize foreign investment and negotiate the economic conditions under which foreign entities participate in petroleum development. At the same time, the sovereign authority to grant such rights remains vested in Venezuela.
3.2 Foreign Rights Under Venezuelan Sovereignty
A state does not necessarily relinquish permanent sovereignty merely because foreign companies receive valuable, extensive, or long-term rights. The decisive issue is the legal character and source of those rights.
An operator may receive authority to extract petroleum. A company may own shares in a petroleum venture. A contractor may receive part of the production as remuneration. A purchaser may obtain preferential access to crude. These arrangements can transfer substantial economic value without transferring sovereignty over the natural resources themselves.
Venezuela’s 2026 hydrocarbons framework reflects this separation. Private operators may undertake primary petroleum activities under contracts with wholly state-owned enterprises or their subsidiaries, assume financial and operational responsibility, receive production-based compensation, and use assigned operational areas. The Republic nevertheless retains ownership of the deposits (Venezuela, 2026, arts. 40–42).
Foreign participation can thus be extensive without contradicting permanent sovereignty as a matter of principle. The harder questions concern the authority under which rights were granted, the legal form of the relevant instruments, the validity of consent, compliance with domestic procedures, and the scope of the rights themselves.
Permanent sovereignty establishes the sovereign baseline. It does not, without further analysis, determine whether a particular contract, concession, corporate arrangement, or international agreement is valid.
4. Venezuela's Constitutional Ownership of Petroleum
Venezuela’s domestic petroleum regime is central to the legal assessment because ownership of hydrocarbons, reservation of petroleum activities, state participation, and private operating rights are governed by separate constitutional and statutory provisions.
The Constitution protects public ownership of hydrocarbon deposits while allowing legislation to determine the institutional mechanisms through which petroleum activities are performed. The 2026 reform broadened the forms of private participation in primary activities without transferring ownership of the deposits.
4.1 State Ownership of Hydrocarbons
Article 12 of the Constitution establishes the starting point. Mining and hydrocarbon deposits located within Venezuelan territory, beneath the territorial sea, within the exclusive economic zone, and on the continental shelf belong to the Republic. They form part of the public domain and are inalienable and imprescriptible (Constitution of Venezuela, 1999, art. 12).
Article 302 addresses petroleum activity rather than ownership of the deposits. It provides that the state reserves, through the relevant organic law and for reasons of national interest, petroleum activity and other industries, services, exploitations, and assets considered strategic or of public interest (Constitution of Venezuela, 1999, art. 302).
The Organic Hydrocarbons Law gives statutory effect to that reservation. Article 10 classifies exploration, extraction, gathering, initial transportation, and storage as primary activities and reserves them to the state under the terms established by the law (Venezuela, 2026, art. 10).
Reservation does not require every operational act to be performed directly by a ministry or wholly state-owned company. The legislation determines the permitted institutional forms through which the reserved activity may be carried out, including qualifying arrangements with private operators.
Article 68 provides one of the clearest statutory safeguards of state ownership. Even where an operator receives authorization to commercialize natural hydrocarbons directly, that authorization does not transfer title to the deposits or permit security interests over the deposits or sovereign rights (Venezuela, 2026, art. 68).
4.2 PDVSA and Private Participation
Article 303 of the Constitution requires the state to retain all shares of Petróleos de Venezuela, S.A. The same provision distinguishes PDVSA itself from subsidiaries, strategic associations, companies, and other entities established through its business activities, which are not subject to the same constitutional requirement of total state shareholding (Constitution of Venezuela, 1999, art. 303).
The 2026 Organic Hydrocarbons Law permits primary activities to be conducted through several institutional routes. They may be performed directly by the national executive or wholly state-owned enterprises; by mixed enterprises in which the Republic or another public entity holds more than 50 percent of the capital and shareholder control; or by private companies domiciled in Venezuela acting under contracts with wholly state-owned enterprises or their subsidiaries (Venezuela, 2026, art. 23).
The contractual route expands the scope for private operation. Article 40 permits a wholly state-owned enterprise or its subsidiary to contract with a private company domiciled in Venezuela for the performance of primary activities. The operator may assume integrated management at its own cost, account, and risk, subject to the statutory requirements concerning financial capacity, technical competence, and the relevant business plan. The Republic retains ownership of the hydrocarbon deposits (Venezuela, 2026, art. 40).
The operator may receive a percentage of measured production as remuneration and, where authorized, commercialize qualifying volumes directly. Temporary rights over operational areas and assets may also be granted, but those rights terminate with the underlying contract (Venezuela, 2026, arts. 41–42).
Mixed enterprises remain a separate route. Their public ownership must exceed 50 percent and include shareholder control. Article 34 provides for presidential authorization and notification to the National Assembly for parliamentary oversight, while Article 35 sets a maximum initial term of 25 years and permits an extension of up to 15 years (Venezuela, 2026, arts. 34–35).
Current Venezuelan law can consequently accommodate extensive private operational participation without privatizing PDVSA or transferring ownership of the petroleum deposits. What remains unknown is which statutory model, if any, governs the commercial arrangements associated with the announced U.S.–Venezuela project.
4.3 Domestic Approval and Constitutional Limits
Domestic validity depends on both the substance of the petroleum arrangement and the legal form of the instruments through which it is implemented. Approval requirements may differ for a mixed enterprise, a private operating contract, a public-interest contract involving a foreign entity, and a treaty between Venezuela and another state.
Article 34 of the 2026 Organic Hydrocarbons Law provides for presidential authorization of mixed enterprises and subsequent notification to the National Assembly for parliamentary oversight. That statutory mechanism does not resolve every constitutional approval issue that could arise from the wider bilateral arrangement.
Article 150 of the Constitution governs public-interest contracts. It provides that national public-interest contracts require National Assembly approval in the cases determined by law. It also establishes a specific rule for public-interest contracts concluded with foreign states, foreign official entities, or companies not domiciled in Venezuela, which may require parliamentary approval (Constitution of Venezuela, 1999, art. 150).
The identity and domicile of the parties are consequently significant. The contractual mechanism created by Articles 23 and 40 of the 2026 Organic Hydrocarbons Law is expressly framed around private companies domiciled in Venezuela contracting with wholly state-owned Venezuelan enterprises or their subsidiaries. A direct agreement involving the U.S. government, another foreign public entity, or a company not domiciled in Venezuela could engage a different constitutional analysis.
A separate constitutional rule applies if the announced bilateral project constitutes a treaty. Article 154 requires treaties concluded by the Republic to receive National Assembly approval before presidential ratification, subject to specified exceptions for certain categories of international instruments (Constitution of Venezuela, 1999, art. 154).
The public record does not yet establish that the 25-year arrangement is a treaty. It could instead be another form of international commitment, a political framework implemented through domestic petroleum contracts, or a combination of several instruments.
A definitive conclusion on Venezuelan constitutional approval is consequently premature. The 2026 reform provides greater statutory flexibility for private petroleum participation, but that flexibility does not displace constitutional requirements that may apply to particular contracts or international agreements. The legal form of the arrangement, the identity and domicile of the parties, and the approvals actually obtained will determine the domestic-law position.
5. What Kind of Legal Instrument Is the Deal?
The expression “oil deal” does not identify a legal category. A large cross-border petroleum project may rest on several instruments at once: an arrangement between governments, contracts between state-owned and private companies, corporate documents establishing a joint venture, operating rights over particular fields, and separate agreements governing production or sales.
Each layer may be governed by a different body of law. International law may regulate commitments undertaken between states. Venezuelan law governs domestic petroleum authorizations and corporate structures. Commercial agreements may be subject to Venezuelan law, another chosen legal system, or agreed arbitration rules. The political announcement does not reveal how these elements have been combined.
5.1 Interstate Framework or Treaty
Article 2(1)(a) of the Vienna Convention on the Law of Treaties provides a widely used codified formulation of a treaty as a written international agreement concluded between states and governed by international law, whatever its designation (Vienna Convention on the Law of Treaties, 1969, art. 2). That definition governs the Convention itself; it does not exhaust the possible forms through which states may undertake international obligations.
The announced 25-year arrangement could constitute a treaty or another binding international agreement if the United States and Venezuela intended to create legal obligations governed by international law. Relevant indicators would include the identity of the parties, the language of commitment, entry-into-force provisions, duration and termination clauses, and the relationship between the government-level arrangement and the petroleum contracts implementing it.
Public statements do not resolve those questions. Rodríguez has described a 25-year bilateral project, and public reporting refers to an energy agreement, but the governing interstate text has not been disclosed (Reuters, 2026). What is uncertain is not whether a bilateral arrangement has been announced, but whether it has been embodied in a written instrument governed by international law and, if so, what obligations that instrument creates.
A government-level commitment would not automatically determine the rights of companies operating the fields. An interstate framework could establish political or legal commitments between the two states while leaving exploration, production, financing, management, and sales to separate instruments governed primarily by Venezuelan or commercial law.
5.2 Concessions, Licenses and Joint Ventures
Petroleum rights may arise through instruments legally distinct from the relationship between the United States and Venezuela. A company may receive operating authority, an equity interest, production-based remuneration, temporary rights over operational areas, or authorization to market crude without becoming a party to an international agreement between the two states.
Venezuela’s 2026 Organic Hydrocarbons Law expressly permits several forms of participation. Primary activities may be conducted through wholly state-owned enterprises, mixed enterprises with majority public ownership and shareholder control, or qualifying private companies domiciled in Venezuela operating under contracts with wholly state-owned enterprises or their subsidiaries (Venezuela, 2026, art. 23).
The distinction between state and company is equally important on the U.S. side. A petroleum right held by Chevron or another American corporation is not, merely because the company is American, a sovereign right of the United States. Corporate nationality does not transform contractual or proprietary interests into territorial authority or ownership of Venezuelan natural resources.
The analysis becomes more complicated if the U.S. government itself holds an interest in the new commercial structure, as AP has reported on the basis of an unnamed U.S. official (Associated Press, 2026). Government ownership may create a direct U.S. economic interest, but it does not eliminate the separate legal personality of the company or convert the company’s petroleum rights into U.S. sovereignty. Under the law of state responsibility, corporate conduct is not attributed to a state merely because the state owns an interest in the entity; attribution depends on the applicable rules concerning governmental authority, instruction, direction, or control (International Law Commission, 2001).
5.3 Reconciling the 25-Year and 100-Year Terms
The reported durations illustrate why the transaction cannot yet be treated as a single legal instrument. Rodríguez has publicly described a 25-year bilateral project. AP has separately reported, citing an unnamed U.S. official, that rights associated with specified oilfields could extend for as long as 100 years (Reuters, 2026; Associated Press, 2026).
Those periods are not necessarily incompatible. An interstate framework may operate for one period while field rights, corporate arrangements, contractual options, or other commercial entitlements continue for another. Different instruments within the same economic project need not share identical expiration dates.
The available evidence does not establish that this is the structure actually adopted. The reported 100-year term cannot yet be characterized confidently as a concession, license, operating right, corporate entitlement, renewable authorization, or another form of petroleum right.
The distinction is especially significant because Venezuelan law imposes specific duration rules on certain petroleum structures. Mixed enterprises, for example, have a maximum initial term of 25 years, with a possible extension of up to 15 years (Venezuela, 2026, art. 35). A reported 100-year entitlement would consequently require examination of its particular legal basis rather than an assumption that it constitutes an ordinary mixed-enterprise term.
6. Treaty Law and the Validity of State Consent
The Vienna Convention provides the principal codified framework for treaty validity, performance, and termination, but its status in the U.S.–Venezuela relationship requires qualification. Neither the United States nor Venezuela is a party to the 1969 Convention. The United States signed it in 1970 but has never ratified it, while Venezuela is not listed as a signatory or party (United Nations Treaty Collection, 2026).
The Convention consequently does not bind the two states as a treaty. Its provisions remain relevant where they codify or reflect customary international law. The U.S. Department of State has itself stated that the United States considers many provisions of the Convention to constitute customary international law (U.S. Department of State, n.d.).
This distinction affects the analysis of good-faith performance, reliance on internal law, constitutional competence, and coercion. The Convention provides useful formulations of these rules, but their bilateral application depends on their status in general international law rather than on treaty participation in the VCLT itself.
6.1 Pacta Sunt Servanda and Internal Law
Pacta sunt servanda remains the starting point. A treaty in force binds its parties and must be performed in good faith. Article 26 of the VCLT codifies a principle that long predates the Convention and forms part of the general law of treaties (Vienna Convention on the Law of Treaties, 1969, art. 26).
A state also cannot ordinarily rely on its internal law as justification for failing to perform an international obligation. Article 27 expresses that rule while preserving the separate issue of whether a serious defect in domestic treaty-making competence may have affected the original validity of consent.
The distinction between invalidity and non-performance is important. If Venezuela validly undertook an international obligation, a later domestic political disagreement or legislative change would not by itself extinguish that obligation. Domestic law may determine what Venezuelan authorities can do internally, but it does not automatically decide whether the state remains bound internationally.
The same applies to the United States. Domestic questions concerning presidential authority, congressional participation, appropriations, or agency competence may affect U.S. law without necessarily deciding whether an international commitment exists at the international level.
6.2 Article 46 and Constitutional Violations
Article 46 addresses the narrower situation in which a state seeks to invalidate its consent because the official who expressed it acted contrary to internal rules governing competence to conclude treaties. The provision sets a demanding threshold.
The rule permits reliance on such a violation only when it is manifest and concerns a rule of internal law of fundamental importance. A violation is manifest when it would have been objectively evident to another state acting in accordance with normal practice and good faith (Vienna Convention on the Law of Treaties, 1969, art. 46).
The International Court of Justice applied a restrictive approach in Land and Maritime Boundary between Cameroon and Nigeria. Nigeria argued that constitutional requirements had not been followed when its Head of State signed the Maroua Declaration. The Court emphasized the importance of the manifest-violation requirement and rejected the proposition that an undisclosed domestic restriction could readily invalidate the state’s international consent (ICJ, 2002, para. 265).
Any Venezuelan constitutional objection would consequently require two distinct inquiries. The first is whether Venezuelan law was actually violated—for example, because parliamentary approval required under Articles 150 or 154 was omitted. The second is whether the defect was of a kind capable of affecting Venezuela’s consent under the applicable international-law rule.
No definitive answer is possible while the juridical form of the 25-year arrangement and the approval process remain unknown. A domestic petroleum contract, a public-interest contract involving a foreign party, and an international agreement are subject to different constitutional requirements.
7. Coercion, Pressure and Article 52 of the VCLT
The most difficult question concerning Venezuela’s consent arises from the political and military circumstances surrounding the arrangement. The United States conducted a military operation in Venezuela on January 3, 2026, resulting in the capture and removal of Nicolás Maduro. Trump later indicated that further military action remained possible if Venezuelan authorities did not cooperate (Reuters, 2026).
Those circumstances make coercion a legitimate subject of legal analysis. They do not establish that the August petroleum arrangement was itself procured by unlawful force. Treaty invalidity on that basis requires more than evidence of unequal bargaining power, sanctions, political dependence, or a prior military confrontation.
7.1 Military Force and Treaty Consent
Article 52 of the VCLT states that a treaty is void if its conclusion has been procured by the threat or use of force in violation of the principles of international law embodied in the UN Charter (Vienna Convention on the Law of Treaties, 1969, art. 52).
The International Court of Justice has treated the underlying rule as part of contemporary international law. In Fisheries Jurisdiction, the Court stated that an agreement concluded under the threat or use of force is void, while also emphasizing that an allegation of coercion must be supported by evidence rather than asserted in vague terms (ICJ, 1973, para. 24).
The requirement that the agreement have been “procured” by force is central. The existence of unlawful force somewhere in the relationship between two states does not automatically invalidate every agreement subsequently concluded between them. A sufficient connection must exist between the prohibited threat or use of force and the consent through which the agreement was obtained.
The January operation and subsequent statements concerning possible additional force form part of the factual context. The public record, however, does not establish that Venezuelan officials were told that military action would be renewed unless they accepted particular petroleum terms.
Rodríguez has publicly portrayed the arrangement as a negotiated project and has insisted that Venezuela retains ownership and sovereignty over its natural resources (Reuters, 2026). That characterization is relevant but not conclusive. The legal issue remains how consent was obtained.
7.2 Sanctions and Economic Pressure
Economic and diplomatic pressure present a more difficult question. Venezuela has operated for years under extensive U.S. sanctions, and changes in American licensing policy have directly affected the capacity of Venezuelan petroleum enterprises and foreign partners to market crude, receive payments, and maintain commercial operations.
Such measures can substantially alter bargaining power. Article 52, however, refers to the threat or use of force contrary to the principles of the UN Charter. Economic pressure has not acquired general acceptance as equivalent to “force” for purposes of the treaty-invalidity rule reflected in Article 52.
The drafting history reinforces this distinction. During the work leading to the Convention, proposals and discussions addressed broader forms of economic and political pressure. The final treaty provision retained the narrower language of threat or use of force, while the Vienna Conference separately adopted a declaration condemning military, political, and economic coercion in the conclusion of treaties (International Law Commission, 1966; United Nations Conference on the Law of Treaties, 1969).
Political or economic measures may raise other questions under international law depending on their nature. They cannot automatically be treated as the form of coercion that renders a treaty void under the rule reflected in Article 52.
Venezuela may consequently have negotiated under severe economic and strategic pressure without that circumstance alone establishing treaty invalidity.
7.3 What Evidence Could Establish Coercion
The analysis would change materially if evidence emerged connecting U.S. military threats directly to acceptance of the petroleum arrangement. Communications stating that Venezuela had to accept specific oil terms to avoid renewed military action would bear directly on the rule reflected in Article 52.
Threats directed personally at Rodríguez or another representative would raise a separate issue. The rule reflected in Article 51 of the VCLT treats a state’s expression of consent as legally ineffective when it has been procured through coercion of its representative by acts or threats directed against that person (Vienna Convention on the Law of Treaties, 1969, art. 51).
Contemporaneous diplomatic communications, negotiating records, instructions to Venezuelan officials, military warnings tied specifically to the petroleum negotiations, or credible testimony from participants could alter the legal assessment. Evidence showing that acceptance of particular terms was made an express condition for avoiding prohibited force would be especially significant.
No such evidence has been made public. The established circumstances include prior U.S. military action, subsequent threats of further action, extensive sanctions, and pronounced inequality in bargaining power. Those facts warrant scrutiny, but they do not presently establish the legal nexus required to conclude that Venezuela’s consent to the petroleum arrangement was procured by unlawful force.
8. The Legal Position of U.S. Companies
The rights of American companies must be distinguished from the rights and obligations of the United States. A company operating in Venezuela may possess contractual or corporate interests without exercising sovereign authority. Conversely, the U.S. government may possess international rights against Venezuela without owning assets held by a private American corporation.
This separation becomes particularly important if the project combines government participation with private operators. The applicable legal regime may change according to the identity of the party asserting the relevant right.
8.1 Contractual Rights Versus Sovereign Rights
An American company could acquire an equity interest in a petroleum venture, operating authority over particular fields, a contractual share of production, purchasing rights, revenue entitlements, or temporary rights over operational assets. Venezuelan law permits several forms of private participation of this kind.
These interests are proprietary or contractual. They do not confer sovereign jurisdiction over Venezuelan territory or petroleum deposits. The Constitution and the 2026 hydrocarbons legislation preserve the Republic’s ownership of the deposits even where substantial operational functions are exercised by private actors.
American nationality also does not transform corporate rights into rights of the United States itself. A company ordinarily possesses separate legal personality, and international law distinguishes corporate rights from claims that the company’s national state may in some circumstances espouse or protect.
The position would differ if the U.S. government itself held equity or contractual interests. AP has reported government participation in the proposed commercial structure, although the underlying instruments remain unavailable (Associated Press, 2026). Even in that situation, an economic interest in a company would remain legally distinct from sovereignty over Venezuela’s petroleum resources.
8.2 Expropriation, Compensation and Arbitration
Long-term petroleum rights raise the question of what would happen if Venezuela later nationalized, terminated, or substantially restructured them. There is no single international remedy that would automatically apply to every American investor involved in the project.
UNCTAD’s current investment-treaty database does not list a bilateral investment treaty between the United States and Venezuela (UNCTAD, 2026). A U.S. investor therefore cannot assume the protection of a U.S.–Venezuela BIT containing investor-state arbitration.
Venezuela denounced the ICSID Convention in 2012, with the denunciation taking effect on July 25 of that year (ICSID, 2012). Convention membership therefore cannot provide an automatic jurisdictional basis for disputes arising from new investments. Arbitration administered by ICSID or another institution could still be possible where a separate basis of consent and the relevant jurisdictional requirements are satisfied.
Venezuela is also a party to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, subject to reciprocity and commercial reservations (United Nations Treaty Collection, 2026). The Convention can facilitate recognition and enforcement of qualifying arbitral awards, but it does not itself create consent to arbitration.
The governing contracts will consequently be critical. They may designate Venezuelan courts, international commercial arbitration, another agreed forum, governing law, compensation mechanisms, or procedures for termination and expropriation. Until those provisions are known, the forum and substantive protections applicable to a future dispute cannot be determined.
8.3 Existing Investors and Competing Petroleum Rights
The announced arrangement enters a petroleum sector in which foreign companies already hold significant interests. Chevron increased its working interest in Petroindependencia to 49 percent in April 2026, while Petropiar obtained development rights over the adjacent Ayacucho 8 area (Chevron, 2026).
Other international companies also remain active in Venezuela. Eni has maintained petroleum and gas interests with PDVSA, while Repsol reached new arrangements in 2026 concerning operational control and increased production at Petroquiriquire. Other foreign operators have likewise participated in Venezuela’s recent restructuring of the sector (Repsol, 2026; Reuters, 2026).
Earlier nationalizations continue to shape the legal background. ConocoPhillips has pursued enforcement and collection arising from arbitral awards connected with Venezuela’s earlier expropriation of petroleum investments, while ExxonMobil has also obtained arbitral relief arising from Venezuelan nationalization measures (ICSID, 2023; ConocoPhillips, 2026).
Those disputes demonstrate that sovereign restructuring of the petroleum sector may generate long-running questions of compensation, jurisdiction, and enforcement. They do not establish that the new U.S. arrangement conflicts with existing investors.
There is presently no public basis for concluding that the 17 fields associated with the new project unlawfully overlap with prior contractual rights. That question requires identification of the fields, corporate parties, existing encumbrances, and new grants.
9. Can a Future Venezuelan Government Undo the Deal?
A change of government does not ordinarily alter the international legal identity of the state. Venezuela remains the same international legal person when one administration replaces another, and valid obligations of the state do not disappear merely because political leadership or policy changes (Crawford, 2019).
A future administration could oppose the economic or political wisdom of the arrangement and seek to renegotiate it. The legal consequences would depend on whether the rights at issue arise from an international agreement, Venezuelan public law, a petroleum contract, a corporate instrument, or several legal sources operating together.
9.1 State Continuity After a Change of Government
International obligations attach to the state rather than to the particular government that negotiated them. Elections, constitutional transitions, changes in political ideology, or replacement of officeholders do not ordinarily create a new state or extinguish validly assumed obligations.
A later Venezuelan government could argue that an arrangement was invalid from its inception because officials lacked constitutional authority, required procedures were omitted, or consent was procured unlawfully. Those are challenges to validity. They differ from the proposition that a valid obligation disappears merely because a successor government rejects the policy underlying it.
The same distinction applies to responsibility for internationally wrongful acts. Changes of government do not normally interrupt the continuity of the state to which conduct is attributable (International Law Commission, 2001).
9.2 Repudiating a Treaty or Terminating a Contract
If part of the arrangement constitutes a binding international agreement, termination will depend first on its own provisions and on the applicable rules of international law. The VCLT codifies recognized grounds including termination in accordance with the treaty, termination by consent, material breach, supervening impossibility, and fundamental change of circumstances.
Neither the United States nor Venezuela is a party to the VCLT, so those provisions do not apply between them by force of the Convention itself. The International Court of Justice has nevertheless recognized that several rules concerning termination and suspension, including those reflected in Articles 60–62, correspond to customary international law (ICJ, 1997).
The doctrine of fundamental change of circumstances is particularly restrictive. In Gabčíkovo–Nagymaros Project, the Court emphasized its exceptional character and rejected reliance on changed political and economic circumstances that did not satisfy the required conditions (ICJ, 1997).
A change in government policy would consequently not provide a general right to abandon a binding international commitment.
Commercial contracts follow a different legal route. Their termination depends on the governing law, termination provisions, regulatory powers, contractual remedies, force-majeure clauses, and any dispute-settlement mechanism. Venezuela may possess domestic authority to alter or terminate a petroleum right while still incurring contractual or international consequences.
The stated duration of a right does not settle its legal durability. A 25-year or reported 100-year term indicates an intended period of operation, not immunity from lawful termination, renegotiation, expropriation, or challenge.
9.3 Nationalization and Compensation
Permanent sovereignty over natural resources includes the authority of the state to determine the organization of its resource sector. It does not establish that every nationalization can occur without legal consequences.
Resolution 1803 recognizes nationalization, expropriation, and requisition for reasons of public utility, security, or national interest and addresses compensation within the applicable domestic and international legal framework (UN General Assembly, 1962).
The consequences of any future Venezuelan nationalization would depend on the rights affected. A contractual compensation provision may establish one standard. An applicable investment treaty could establish another where a qualifying investor benefits from its protection. Venezuelan law would govern additional aspects of the measure, while general international law may become relevant where foreign property is affected.
No U.S.–Venezuela bilateral investment treaty currently provides a general investment-protection regime for American investors. Permanent sovereignty likewise does not extinguish contractual obligations that Venezuela has validly undertaken.
A future government could consequently seek greater state control over petroleum operations while remaining exposed to compensation claims or other legal remedies. The existence and extent of such liability cannot be determined until the relevant contractual and investment rights are known.
10. What the Published Terms Still Cannot Establish
The principal limitation on the legal analysis remains documentary. Political statements reveal considerably more about the economic ambition of the arrangement than about its legal architecture.
Reuters reported on August 30 that specific petroleum contracts involving foreign companies were expected to follow the broader announcement (Reuters, 2026). Until those instruments and any written government-level documentation become available, several important legal conclusions remain provisional.
10.1 The Missing Agreement Texts
A definitive assessment requires more than the announced 25-year duration and production targets. Any written interstate instrument would be necessary to determine whether the United States and Venezuela have undertaken binding obligations governed by international law and what those obligations contain.
Field-level documentation is equally important. Agreements covering the 17 strategic fields and eight greenfield blocks would identify operators, duration of rights, production entitlements, regulatory obligations, investment commitments, and conditions governing termination or transfer.
Corporate documents would clarify the reported 55 percent effective-output arrangement. Incorporation instruments, shareholder agreements, voting arrangements, capital contributions, management provisions, and purchasing rights would show what form of economic or corporate control U.S. interests actually possess.
Domestic approvals would also be relevant. Presidential authorizations, National Assembly action where constitutionally required, Ministry of Hydrocarbons decisions, PDVSA agreements, and applicable publication in the Gaceta Oficial would permit the domestic validity of the arrangements to be assessed against the Constitution and the 2026 Organic Hydrocarbons Law.
Without these materials, political descriptions of “control,” “ownership,” and “sovereignty” cannot substitute for legal characterization.
10.2 Parties, Governing Law and Dispute Settlement
The identity of the contracting parties may prove as important as the headline economic terms. A contract between PDVSA and a Venezuelan-incorporated subsidiary of an American company raises different legal questions from an agreement directly between Venezuela and the U.S. government.
Governing-law clauses will determine which legal system regulates contractual interpretation, performance, termination, and remedies. Dispute-settlement provisions may direct disagreements to Venezuelan courts, international arbitration, interstate negotiation, or another forum.
Duration provisions also require context. A nominal 100-year entitlement could contain renewal conditions, termination rights, production obligations, relinquishment requirements, regulatory review, or other limitations. Duration alone does not establish the practical strength of a petroleum right.
The same caution applies to stabilization clauses. Such provisions, if included, may regulate the consequences of future legislative or fiscal changes, but their existence cannot be presumed. Assignment provisions, change-of-control clauses, compensation formulas, force-majeure rules, and production-allocation mechanisms may be equally significant.
These terms will ultimately determine what “majority control” means in legal terms. It may refer to corporate governance, access to production, contractual purchasing power, operational management, direct government participation, or some combination of those elements. The public record does not yet permit a more definitive conclusion.
Also read
Conclusion
The U.S.–Venezuela oil arrangement can accommodate substantial American economic and operational influence without transferring Venezuelan ownership of its petroleum deposits or sovereignty over its natural resources. Control, ownership, and sovereignty remain distinct legal concepts.
Venezuela’s Constitution places hydrocarbon deposits in the public domain of the Republic, while the 2026 hydrocarbons legislation permits extensive private participation in extraction, management, production-based remuneration, and commercialization without transferring ownership of those deposits. International law likewise permits a state to authorize extensive foreign exploitation while retaining permanent sovereignty over its natural resources.
The more difficult questions concern the rights actually created. The announced 25-year project, the claim of control over more than 65 billion barrels, the reported 55 percent effective-output position, and the reported rights extending for up to 100 years cannot be treated as interchangeable descriptions of ownership.
Treaty law introduces an additional qualification. Neither the United States nor Venezuela is a party to the 1969 Vienna Convention on the Law of Treaties, although important provisions of the Convention reflect customary international law. Questions concerning constitutional competence, coercion, performance, and termination must consequently be grounded in the applicable rules of general international law rather than on an assumption that the Convention binds both states as a treaty.
The circumstances surrounding Venezuela’s consent require careful scrutiny. Prior U.S. military action, subsequent threats of further action, sanctions, and pronounced inequality in bargaining power form part of the factual context. They do not, without evidence connecting prohibited force to acceptance of the petroleum terms, establish that Venezuela’s consent was legally procured by coercion.
The durability of the commercial rights is similarly dependent on their legal basis. A future Venezuelan government would not extinguish valid state obligations merely by replacing the administration that accepted them, although it could seek renegotiation, termination, restructuring, or nationalization under the applicable legal regimes. Any resulting compensation or liability would depend on the contracts, Venezuelan law, applicable international obligations, and agreed dispute-settlement mechanisms.
The strongest conclusion permitted by the present record is narrower. U.S. control over petroleum production, corporate decision-making, purchasing rights, or economic output can coexist with Venezuelan ownership of the deposits and Venezuela’s sovereign authority over the resource base. Whether the U.S.–Venezuela oil deal actually creates that legal structure will depend on instruments whose full terms have not yet been made public.
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