Venezuela Upstream July 2026: LOH Regulation drops PDVSA (Gaceta 7,052), Repsol signs Horcón MoU, OFAC amends GL 46C-54A, Brent normalizes to $81

Venezuela's upstream just received the most consequential change to its legal framework in more than eight decades. The Organic Hydrocarbons Law Regulation —Decree No. 5,381, Official Gazette Extraordinary 7,052, in force since its publication on July 7, under the Ministry of Hydrocarbons (Paula Henao)— is the first comprehensive regulation of the law since 1943, consolidating into a single text a body of rules previously scattered across more than a thousand resolutions. Its most consequential feature for the investor sits in the technical detail, not the headline: the text never names PDVSA —it always uses the formula "company wholly owned by the Republic or its subsidiaries"— but the State does not stop being a mandatory counterparty. The Regulation's own definition of "Operating Companies" (Art. 2) requires every private party to be either a partner in a state-majority Joint Venture, or a signatory to one or more contracts with that state-owned company. What does change is that the Regulation formalizes that second path —a purely contractual "Business Model," without a joint equity company (Art. 14, referencing Art. 23 of the Law)— as an explicit alternative to the traditional joint venture: a private operator no longer needs to cede equity inside a shared entity to access acreage and run the chain, but it still does so under contract with the State, not independently of it.