12 Billion Dollars A confidential KPMG review shows where the dollars went, and where nobody is looking

Part 1A ledger, not a lens

For the first time since Iraq two decades ago, the United States is holding a country's oil money and deciding, withdrawal by withdrawal, when it goes home. Now there is a number on it. A confidential report by KPMG, compiled for the US government and first reported by The New York Times on 10 November, shows that $12.26bn flowed into the "Venezuela Custody Account" between 3 January and the end of September from oil and other natural-resource exports. Almost all of it went straight back: about $11.7bn was sold through Venezuelan commercial banks to prop up the bolívar, about $130m paid foreign bills, about $170m was still there on 30 September, and the money earned about $12m in interest while it waited, according to the Times.

The report tells a story in two halves. At the top, the controls are tight: licensed buyers, a Treasury-designated account at Citibank in New York, a request from Venezuela's central bank and a signature from both the State Department and the Treasury on every transaction. At the bottom, the trail goes dark. The report does not identify who ultimately bought the dollars at the bank counter.

That asymmetry is the story. The custody account is a ledger, not a lens: Washington can account for what left New York, but no public document says who ended up holding the dollars. For an arrangement sold as the cure for a regime that Marco Rubio, the secretary of state, says was held together by "corruption and graft", the last mile is the part that matters.

The timing sharpens the point. The report, dated 29 October according to Finanzas Digital, was finished days before the midterm elections that handed Democrats both chambers of Congress, and it is the first detailed accounting of a system that ran for ten months on piecemeal briefings. In April a State Department official told Congress about $3bn had been moved to Venezuela; in July the Financial Times estimated more than $13bn had been collected. The report settles the size. It also shows, by omission, what the system was never built to see.

Part 2How Washington took the till

The account was born of a raid. On 3 January, US forces struck Caracas and seized Nicolás Maduro and his wife, Cilia Flores, who were flown to New York to face drug-trafficking charges. Venezuela's Supreme Court ordered the vice-president, Delcy Rodríguez, to take charge; she was sworn in as interim president on 5 January, with her brother Jorge re-elected speaker of the National Assembly. Ten months on she is still in office, having kept the chavista coalition together while meeting Washington's economic demands, and Donald Trump has publicly praised her work.

Six days after the raid, Mr Trump signed Executive Order 14373. It defines "Foreign Government Deposit Funds", the proceeds of Venezuelan natural-resource sales paid into designated Treasury accounts, declares them Venezuelan sovereign property held in custody, voids any attempt by creditors to seize them and gives the secretary of state the power to direct their use. The model, compliance firm K2 Integrity noted in January, is the order that shielded Iraqi oil proceeds in 2003, though Georgetown's Public Debt is Public project reads the new one as narrower. Licences followed: OFAC's General License 46 of 29 January lets established US firms trade Venezuelan oil on condition that anything owed to Venezuela or PDVSA is paid into those accounts, and later licences extend the rule to services and to BP, Chevron, Eni, Repsol, Shell and Maurel & Prom.

Mr Rubio described the plumbing to senators in late January. "The glue that held the Maduro regime together was corruption and graft," he said, adding that Washington was "dealing with people who have spent most of their lives living in a gangsters' paradise". The first oil, he said, was sold through two trading houses, Trafigura and Vitol, as a "short term" fix; proceeds went into an account in Qatar, and $300m of an initial $500m had already been handed to Caracas. Ten months later the short term looks permanent. The two traders supplied 61% of all deposits by September, about $7.48bn by Le Détroit's calculation, and Trafigura also paid about $100m for Venezuelan gold. Two producers use different arrangements and sell at least some of their oil outside the account: Chevron, and NABEP, a local company that began shipping oil to the United States last month under a deal giving the US government 35% of its shares and 20% of its output at below-market prices, the Times reports.

Part 3From barrel to bolívar

Follow the money and the design is clear: control is concentrated where the money is big and the parties are few. Finanzas Digital, a Caracas financial outlet that has itemised the report, dated 29 October, describes the weekly cycle. The central bank (BCV) decides how much to allocate to each participating bank and asks the State Department for approval; once State and the Treasury sign off, the money moves from the custody account to a BCV operating account and on to the banks, which have five working days, extendable by five more, to credit their clients. The BCV debits the bolívar equivalent at a rate it sets, and those bolívars help pay for the state, from public salaries down.

The mechanics changed as the year went on. In the first quarter, banks ran auctions; from 31 March the central bank switched to electronic sales, which began at $512m in March, peaked at $2.0bn in April, slowed to $765m in August and rebounded to $1.35bn in September, according to Finanzas Digital. From July, physical dollar banknotes were added to the mix. Every dollar still has to pass through US correspondent banks, which screen for sanctions and can block, reject or freeze a transfer, and buyers receive it in local foreign-currency accounts subject to identification checks. That is a real filter. It is also the last one with an American hand on it.

The itemised version closes a gap that the headline numbers leave open. On the Times's rounded figures, about $0.27bn of the money in is not accounted for. On Finanzas Digital's reading, the report lists $2.09bn of currency auctions from January to March, $9.32bn of electronic currency sales from 31 March, $550m of dollar banknotes shipped since July, $133m of payments to suppliers and $169m left on 30 September. Le Détroit's calculation: that leaves about $11m unitemised, less than 0.1% of the total and within rounding.

In other words, the account itself is not where money goes missing. The first $500m passed through a provisional central-bank account at Qatar National Bank before the arrangement moved to New York in late January; since then the books, as described, balance. Two caveats matter. KPMG says its work is not an audit, and the depositors' names are redacted in the version Finanzas Digital saw.

Part 4Barrels in, dollars back

The oil side of the ledger is bigger and better than a year ago, which is why the reconciliation matters. Venezuela exported about 847,000 barrels a day of crude and fuel in 2025, according to Reuters tanker data, and only 498,000 in December, when a US blockade bottled up cargoes. Under US supervision exports recovered to 800,000 in January, passed a million in March and reached 1.23m to 1.25m b/d in April and May, the highest since late 2018. Freight costs and twin earthquakes at the end of June took some of the shine off: exports were 1.08m b/d in September and again in October. In July the United States took 786,000 b/d, its largest volume since early 2019.

Chevron, which exports about 0.3m b/d under its own arrangements, accounts for about a quarter of the country's exports. Strip it out, assuming none of its sales pass through the account, and Le Détroit's calculation is that other buyers loaded about 221m barrels between January and September. Oil supplied 98.74% of deposits, or $12.11bn. That is $55 to $61 per barrel, depending on whether payments lag loadings by a month, while the Venezuelan oil basket averaged about $90 this year, according to Finanzas Digital.

The gap is not proof of anything. Traders pay PDVSA less than benchmark prices to cover freight and quality, part of the volume is fuel oil and by-products, early cargoes were sold before prices rose, and deposits lag loadings. But it is precisely the sum a compliance officer would want reconciled: barrels lifted, price per cargo, deposit per cargo. In July the Financial Times estimated that the administration had collected more than $13bn and that the destination of at least $10bn was unclear. The KPMG report answers the second half of that question, down to the bank. It does not, as described, reconcile the first: what each cargo should have paid.

Part 5Buying time for the bolívar

Almost every dollar that came back was spent defending the currency, and the dollars bought time rather than stability. The government has sold more than $12bn on the foreign-exchange market this year, according to Bloomberg Línea and Finanzas Digital; Sintesis Financiera, a Caracas consultancy, puts sales in the first nine months at $12.3bn, close to the report's figure, the Times reports. Sales climbed from about $500m a month at the start of the year to about $1.7bn by July, economist Jesús Palacios told Bloomberg Línea; the report puts April, at $2.0bn, as the peak. In September they fell to $1.4bn, the lowest since April, according to Sintesis.

The official rate kept sliding all the same. It ended 2025 at about 298 bolívars per dollar, on Finanzas Digital's count, and stood at 911.6 on 13 November, up 206% this year: by Le Détroit's calculation the bolívar has lost 67% of its value against the dollar since January. Prices followed. Inflation was 475% in 2025 and still ran at 225.3% in the year to September, according to the BCV.

Where the sales did work was the gap between the official rate and the street. On the peer-to-peer platforms where Venezuelans trade Tether's USDT, the dollar fetched about 560 bolívars before the raid and more than 780 within days, Decrypt reported, before falling back to 450 by 19 January. It was 710 in May, a premium of 37%, according to CriptoNoticias, and the gap fell below 20% in July. On 7 October the parallel dollar crossed 1,000 bolívars for the first time, with the premium at about 15%. Each dollar sold at the official rate is therefore worth more on the street, and that premium is what makes the question of who buys them so pointed.

Two shocks show how thin the cushion is. Monthly inflation jumped to 13.8% in June, from 6.3% in May, in a month that ended with twin earthquakes, according to Bloomberg Línea, and the government let the official rate slide by more than 8% in a single week, economist Jesús Palacios said. Then, as sales slowed after the summer, the premium crept back. The account can feed the market; it cannot by itself make the bolívar credible.

Part 6Who bought the dollars

The buyers are known by category, not by name. According to Finanzas Digital's reading of the report, companies bought 77% of the dollars and individuals 23%, figures that also include $346m drawn from the IMF, with no disbursements to government entities. Among companies, food and consumer goods took 35.75%, business services 23.69%, agriculture 12.58% and health and pharmaceuticals $531.7m. Twenty banks did the selling, and five of them, Banco de Venezuela, Banesco, Mercantil, BBVA Provincial and Banco Nacional de Crédito, handled 81% of the electronic sales. Banco de Venezuela alone sold $2.42bn.

Earlier reporting points the same way. Earlier Times reporting indicates that a large share of the dollars went to a small group of agribusiness and consumer companies while many smaller firms struggled to get hard currency. In March, five sources told Reuters that large food, healthcare, beverage and chemical companies enjoyed preferred access to the auctions while medium-sized firms went home empty-handed; one businessman in the chemicals sector said "the auctions have been very limited, reaching only a few companies, and are discretionary". Ecoanalítica, a consultancy, estimated in April that 20% to 30% of allocations went to individuals' retail accounts, according to Caracas Chronicles, which argued that buyers with access could resell the dollars on the parallel market at a premium. It also noted that only buyers with foreign accounts able to receive international transfers could take part, which shuts out many small firms by design.

None of this shows wrongdoing. Importers of food and medicine are exactly whom a stabilisation programme would serve first, and big buyers are easier for banks to vet. The problem is verification. Le Détroit's calculation is that, of every $100 paid into the account, about $97.55 was sold through banks, about $75 went to companies and about $27 to food and consumer-goods firms. The amount that went to a buyer named in any public document is zero.

Part 7The compliance officer's questions

Read with an anti-money-laundering eye, the arrangement inverts the usual risk map. Controls cluster at the top, where a handful of licensed traders pay into one account and every withdrawal needs two US signatures. They thin out exactly where the risk concentrates: at the auction, where scarce dollars are sold at an official rate below the street rate, in a country the Financial Action Task Force has kept under increased monitoring since June 2024. A compliance officer would ask five questions. Who are the 20 depositors, and do their payments reconcile with barrels and prices? What are the "financial integrity criteria", in the Times's phrase, applied to each withdrawal? Does anyone aggregate purchases by beneficial owner across the 20 banks? How much of the individuals' 23% was resold on the parallel market? And are any large buyers politically exposed or linked to sanctioned networks?

History suggests where custody fails. In Iraq, the Development Fund held oil money at the New York Fed and was audited by KPMG, yet the US inspector general found that $8.8bn handed to Iraqi ministries lacked adequate controls, with payrolls padded by ghost guards. Under the UN's Oil-for-Food programme, about 2,200 companies paid $1.8bn in kickbacks and surcharges in a programme that sold $64.2bn of Iraqi oil, the Volcker inquiry found, while nearly $11bn more came from smuggling outside it. Afghanistan and Libya show the opposite failure: money so tightly frozen that it bleeds value. Half of Afghanistan's $7bn at the New York Fed went to a Geneva fund in 2022 that had disbursed nothing by March 2023; Libya's sovereign fund says the freeze cost it $4.1bn in forgone returns by 2020. Venezuela's account avoids both traps at the top, since money moves fast and the ledger balances. Its exposure sits where Iraq's did, at the point of disbursement.

Part 8Le Détroit's reading

The custody account solves the problem Washington feared and leaves the one a compliance officer would fear. It keeps creditors' hands off the cash and the Maduro-era middlemen out of the oil trade, and its books, as described, close to within $11m. But it feeds dollars into the oldest rent machine in Venezuela: the sale of scarce hard currency at an official rate below the market. Caracas Chronicles called this official-rate allocation "the very mechanism that wrecked Venezuela's economy in the first place". With the premium at 15%, every $1m bought at the official rate is worth about $150,000 more on the street.

Our reading is that the account's arithmetic will matter less from January than the names at the end of it. Democrats, who won both chambers in the midterms, take over the committees from which their members have spent the year asking for the KPMG contract, the audits and a full accounting of disbursements; in September Rubio said the audits were not yet ready, according to NTN24. Three disclosures would turn the ledger into a lens: the depositors' names with a barrel-by-barrel reconciliation, aggregate purchases by beneficial owner above a threshold, and a genuine audit rather than a review. Until then, the most closely supervised oil money in the world ends its journey in the least visible place: a bank counter in Caracas.

There is a case for patience. Building beneficial-ownership data across 20 banks in a sanctioned economy is slow, and publishing buyers' names could expose firms to pressure. But the alternative is worse for everyone, Washington included. If the dollars it releases end up concentrated in a few hands, the custody account will have financed, under American signatures, the very kind of rent that Mr Rubio says held the old regime together. Verification is the only defence the arrangement has against that charge.