Venezuela
Wyoming
Wyoming asks a Venezuelan founder nothing that it does not ask anyone else. No passport field, no residence test, no visit.
The questions come from elsewhere, and two of them decide almost everything: whether you work for the Venezuelan state, and where you live. This page takes them in that order, on texts read on 5 October 2026.
Two readers, two different answers
A founder in Caracas and a Venezuelan living in Madrid, Bogotá or Panama City share a passport and very little else. Almost every rule below attaches to residence.
| Question | You live in Venezuela | You live elsewhere |
|---|---|---|
| Forming the LLC | Possible if you are not a blocked person | Same |
| Mercury | Closed, by residence | Open to review |
| Relay | Closed | Closed too, by citizenship |
| Wise | Closed, by location | Open where you are |
| Venezuelan tax | Worldwide income | Depends on proof of a new tax residence |
If you have left, read the sanctions and Wyoming sections, then go straight to the diaspora section.
Can a Venezuelan own a Wyoming LLC?
Yes. W.S. 17-29-201 lets "one (1) or more persons" organize an LLC and asks only for a name and a registered agent. The general conditions are in Wyoming LLC for non-residents, and the filing in forming a Wyoming LLC from abroad.
What matters here is that the registered agent is a US person. US sanctions law therefore applies to the service you buy, whatever Wyoming company law says.
What US sanctions on Venezuela block in October 2026
The program targets a government, not a population. OFAC's FAQ 519 says "the Venezuelan people are not subject to comprehensive U.S. sanctions", and FAQ 680 adds that US persons "are not prohibited from engaging in transactions involving the country or people of Venezuela, provided blocked persons" are not involved.
The core text is Executive Order 13884 of 5 August 2019, still listed as in force. It blocks the property of the "Government of Venezuela", and its definition is wider than a ministry.
| Who you are | Status under US sanctions | Can a US agent serve you |
|---|---|---|
| On the SDN List | Blocked | No |
| Acting for or on behalf of the state | Blocked, even if unlisted | Not without an authorization |
| Former state employee or contractor | Authorized by General License 34A | Yes, under that license |
| Current health or education worker | Authorized by General License 34A | Yes, under that license |
| Private individual with no state role | Not blocked | Yes |
The middle rows are the ones guides miss. The definition covers "any person who has acted or purported to act directly or indirectly for or on behalf of" the state. FAQ 680 confirms such persons are blocked "regardless of whether the person appears on" the SDN List.
So a clean name search does not settle the matter for a current public servant or a manager of a state company. That reader needs a sanctions lawyer before a registered agent.
What 2026 changed, and what it left in place
Since January 2026 OFAC has issued a long series of general licenses. Most concern oil, gas, minerals, power and telecommunications. One matters to individuals.
- 8 Mar 2015E.O. 13692, first Venezuela order
- 5 Aug 2019E.O. 13884 blocks the Government of Venezuela
- 5 Nov 2019General License 34A, former state staff
- 9 Jan 2026E.O. 14373 on Venezuelan oil revenue
- 14 Apr 2026General License 57, financial services
- 28 Sep 2026Latest amended general licenses
- General License 57, 14 April 2026. It authorizes financial services to four named Venezuelan banks and to individuals blocked solely under E.O. 13884, current state employees included.
- Its limits. It excludes anyone on the SDN List, unblocks no property, and covers financial services only. Company formation is not a financial service.
- What stayed. E.O. 13884 is still on OFAC's list of authorities. The easing is a set of licenses, not a repeal.
OFAC amended Venezuela licenses on 14, 16 and 28 September 2026. Read the program page on the day you act.
The Wyoming point: the Maduro Regime entry
Since 1 July 2025, Wyoming may dissolve an LLC that is "owned or controlled by" a foreign adversary named in 15 C.F.R. 791.4(a). Five of the six entries are countries. The sixth is "Venezuelan politician Nicolás Maduro (Maduro Regime)".
That entry was unchanged on the eCFR on 5 October 2026, its last cited amendment dating from 6 December 2024. The Secretary of Commerce may revise the list without notice.
The reach of the ground over private owners is unsettled, as the non-resident guide sets out. For Venezuela the two readings land as follows.
| Narrow reading | Broad reading | |
|---|---|---|
| Who is the adversary | The regime itself | The regime, and persons tied to it by the federal definition |
| A private Venezuelan owner | Outside: not owned or controlled by a regime | Arguable: the federal definition reaches a "citizen or resident of" a "country controlled by a foreign adversary" |
| Weak point | "Controlled by" is a question of fact for state-linked owners | Wyoming cites section 791.4(a) only, not that definition |
- What it clearly means: an LLC owned or controlled by the regime, or by a person acting for it, is within the ground on any reading.
- What it does not say: the text never names Venezuela, Venezuelans or Venezuelan residents.
- What nobody has answered: we found no guidance from the Secretary of State and no decision. This page does not choose between the readings.
A founder with a present or past state role should put the question to a Wyoming attorney before filing.
Banking: where residence in Venezuela stops the plan
Sanctions law leaves the private founder alone. Bank policy does not. Each provider publishes a closed list, Venezuela is on all three we read, and each applies a different test.
| Provider | Test applied | Venezuelan resident | Venezuelan citizen abroad |
|---|---|---|---|
| Mercury, edited 30 Sep 2026 | Country of residence | Refused | "May still be eligible, pending application review" |
| Relay | Citizenship or residency of any owner | Refused | Refused, exceptions case by case |
| Wise | Where the user is | Refused | Available in supported countries |
Wise adds a warning for travelers: using an account from a listed country can get it "temporarily restricted". The full comparison is in Wyoming LLC bank account for non-residents.
- 11. Any role for the Venezuelan state, now or before?If yes, check General License 34A and take sanctions advice first
- 22. Any tie that could count as regime control?If yes, ask a Wyoming attorney about the dissolution ground
- 33. Where do you live, with proof?In Venezuela: no provider read is open. Abroad: Mercury or Wise may be
- 44. Only then form the LLCA company without an account still owes its yearly filings
An LLC formed before step 3 is not free to hold. It still owes the Wyoming annual report and the federal Form 5472, as the tax guide for non-residents explains, and the budget is in Wyoming LLC cost.
If you live outside Venezuela
Your case follows your country of residence, with three Venezuelan details left over.
- Relay still tests your passport. Its page refuses an owner who "holds citizenship or residency in a listed country". Ask for the exception in writing before applying.
- Mercury will want proof. Its test is residence, so expect to show a lease, a utility bill or a statement from where you live now.
- Never state a residence you do not have. A false address on a bank form is the one mistake that cannot be repaired.
- Venezuela may still count you as resident for tax. See the next section.
A co-owner who lives elsewhere does not solve a resident's problem. Banks identify every owner of 25% or more, and Relay applies its list to each of them.
What Venezuela taxes
We could not reach the SENIAT website, so this section relies on PwC's summary, last reviewed on 30 September 2026. Treat it as a map, not as the law.
| Rule | What PwC reports |
|---|---|
| Who is resident | More than 183 days in Venezuela in the year, or in the year before |
| Leaving | You stay resident unless you spent over 183 days elsewhere and hold proof of tax residence there |
| Citizens | Presumed domiciled in Venezuela unless they prove otherwise |
| Tax base | Worldwide income for residents |
| Scale | 6% to 34%, in bands set in tax units |
| Low tax jurisdictions | Income from investments there is recognized as it accrues, under the fiscal transparency regime |
Three consequences for the owner of a Wyoming LLC.
- The LLC does not shelter a resident. Profit earned through it is foreign source income of a Venezuelan resident.
- Leaving is a matter of evidence. A certificate from your new tax authority is what ends Venezuelan residence, not the flight.
- The transparency regime is the open question. Whether an LLC that pays no US income tax counts as an investment in a low tax jurisdiction depends on a SENIAT list we did not read. Ask a Venezuelan tax adviser.
The tax treaty: in force, and of limited use
The United States and Venezuela signed an income tax convention in Caracas on 25 January 1999, with effect from 1 January 2000. The IRS still listed it on 5 October 2026.
| Income from US sources | Treaty cap | Without a treaty |
|---|---|---|
| Dividends | 15%, or 5% for a company holding 10% of the votes | 30% |
| Interest | 10%, or 4.95% for financial institutions | 30% |
| Royalties | 5% or 10% by type | 30% |
A single-member LLC with no US business rarely earns any of these. Article 4 treats income through a fiscally transparent entity as the owner's, so the claim belongs to you as a Venezuelan resident, and Article 24 leaves relief to Venezuelan law.
Exchange control: what the law says, and what happens
The sources diverge. Many guides still describe Venezuela as under exchange control since 2003. The current text says otherwise.
- Convenio Cambiario No. 1, published on 7 September 2018 and marked in force by the central bank, states that free convertibility is restored and that "cesan las restricciones sobre las operaciones cambiarias".
- The earlier exchange offences law is marked repealed on the same website.
- Article 32 lets resident individuals hold foreign currency accounts in Venezuelan banks, funded from abroad and movable by transfer.
- Article 57 lets exporters of goods and services keep up to 80% of their foreign currency. Later central bank resolutions were not read.
So the obstacle to funding an LLC from Venezuela is no longer a legal prohibition. It is the absence of a provider willing to open the account at the other end.
The bottom line
For a private Venezuelan with no state role, owning a Wyoming LLC is lawful under the texts read here. The adversary list names a regime, not a nationality, and its reach over private owners is open.
Whether the company is useful is a banking question, and it turns on where you live. From inside Venezuela, none of the three providers we read is open. From abroad, the case is close to ordinary, with Relay as the exception.
Settle those points first. Then see what the Wyoming LLC formation service covers, or talk to a specialist about your situation.
Frequently asked questions
Can a Venezuelan citizen open a Wyoming LLC?
Yes. Wyoming's formation statute sets no nationality or residence condition. US sanctions block the Government of Venezuela and listed persons, not private citizens, so a registered agent may serve a Venezuelan who is not a blocked person.
Are Venezuelans under US sanctions?
Not as a population. OFAC states that the Venezuelan people are not subject to comprehensive sanctions. The blocked group is the Government of Venezuela, which includes people acting for it, plus persons on the SDN List.
I work for the Venezuelan state. Does that change anything?
It can. Executive Order 13884 blocks persons acting for the state even when they are not listed. General License 34A covers former staff and current health and education workers. Others should take sanctions advice first.
Does Wyoming's foreign adversary rule apply to Venezuelans?
The federal list names "Venezuelan politician Nicolás Maduro (Maduro Regime)", not the country. A company controlled by the regime is clearly covered. Whether a private owner could be is unsettled, and no state guidance was found.
Can I open a US business account while living in Venezuela?
Not at Mercury, Relay or Wise, according to their own pages on 5 October 2026. All three name Venezuela. Other providers were not confirmed, and no one can promise an account.
I am Venezuelan but live in another country. Am I refused too?
Not everywhere. Mercury tests residence and may accept you after review. Wise tests where you are. Relay refuses an owner holding the citizenship of a listed country, subject to case by case exceptions.
Do I owe Venezuelan tax on the LLC's profit?
If you are tax resident in Venezuela, your worldwide income is taxable there, at rates PwC reports as 6% to 34%. If you left, residence ends only with proof of tax residence in your new country.
Is Venezuela still under exchange control?
Not in its written law. Convenio Cambiario No. 1 of 7 September 2018 restored free convertibility and is marked in force by the central bank. The practical limit today is finding a bank abroad.
Sources
- OFAC, Venezuela-related sanctions program page: the eight executive orders, the general licenses in force and the recent actions of 14, 16 and 28 September 2026
- OFAC Venezuela FAQs 519 and 680: the Venezuelan people are not under comprehensive sanctions, and persons meeting the Government of Venezuela definition are blocked whether or not they appear on the SDN List
- 15 C.F.R. 791.4(a): the sixth foreign adversary is Venezuelan politician Nicolás Maduro (Maduro Regime), not the country of Venezuela
- United States and Venezuela income tax convention, signed in Caracas on 25 January 1999: residence, fiscally transparent entities, and the withholding caps on dividends, interest and royalties
- Banco Central de Venezuela, Convenio Cambiario No. 1, Gaceta Oficial No. 6.405 Extraordinario of 7 September 2018: free convertibility restored, foreign currency accounts for residents
Official, read on 5 October 2026: OFAC's Venezuela program page, Executive Orders 13884 and 14373, General Licenses 34A, 56, 57 and 48D, FAQs 505, 519, 665 and 680, 15 C.F.R. 791.2 and 791.4 on the eCFR, the 1999 income tax convention on irs.gov, and Convenio Cambiario No. 1 on the Banco Central de Venezuela website, where it is marked in force. Read on each provider's own page the same day: the country lists of Mercury (edited 30 September 2026), Relay and Wise. Secondary source, because the SENIAT website could not be reached: the Venezuelan residence test, worldwide taxation, the 6% to 34% scale and the international fiscal transparency regime are taken from PwC Worldwide Tax Summaries, last reviewed 30 September 2026, and no article of the Ley de Impuesto sobre la Renta was read. Not read at all: the SENIAT list of low tax jurisdictions, Banco Central resolutions issued after 2018, and the policies of Stripe, Payoneer and PayPal. To reconfirm before acting: every OFAC text, since general licenses were amended three times in September 2026 alone, the federal adversary list, and how Wyoming applies its dissolution ground, on which no guidance was found. This is not legal or tax advice.