S&P 500 Venezuela Exposure Register

How we audit S&P 500 exposure to Venezuela

Every profile in this register is built from three sources. We screen each company and its named officers against the US Treasury’s consolidated OFAC Specially Designated Nationals list. We read the company’s own SEC filings on EDGAR for Venezuela, PDVSA, Citgo, or sanctions disclosures. And a Caracas Research analyst reviews the result before it is published. The screen re-runs daily, so a new designation or a fresh 10-K disclosure shows up here without waiting for a manual update.

How to read the register

Each company is tagged with one of four exposure levels, and the tag is the fastest way to read the table below:

• Direct — the company itself, a subsidiary, or a named officer appears on the OFAC SDN list, or it discloses operations, assets, or contracts inside Venezuela.
• Indirect — exposure runs through a supplier, a joint-venture partner, a counterparty, or a financial position rather than the company’s own operations.
• Historical — the company had Venezuela exposure that has since been exited, written down, or wound up, but the record still matters for due diligence.
• No record on file — our screen found no Venezuela link. That is an absence of evidence in public sources, not a guarantee, so we say so plainly.

What the 503 audited companies show

Across the 503 S&P 500 names we track, 4 carry direct Venezuela exposure, 3 carry indirect exposure, and 15 show historical exposure that has since unwound. The concentration is unsurprising: energy and financial names dominate the direct tier, because Venezuela’s sanctioned economy still runs through oil, refining, and the bond market. The remainder of the register shows no Venezuela exposure on record — useful confirmation when you are clearing a counterparty rather than investigating one. Open any company for the underlying OFAC matches, the specific filings we read, and the analyst note behind its tag.

Why exposure is easy to miss on a plain OFAC search

A name-only search of the SDN list understates real exposure, because OFAC’s 50% Rule automatically blocks any entity a designated person or company owns 50% or more of — even if that subsidiary never appears on the list by name. A holding company can be SDN-clean on paper while its majority-owned Venezuelan joint venture is not. SEC disclosure has its own gap in the other direction: a Venezuela position only has to be flagged in a 10-K or 20-F once it crosses the filer’s own materiality threshold, so a position that is small relative to a company’s total balance sheet can go unmentioned in the filing even though the underlying sanctions exposure is real. That is why this register cross-checks OFAC ownership logic against SEC filing text instead of relying on either source alone, and why “indirect” is its own tag rather than being folded into “none.”