OFAC GL 51A, 54, 55 for Venezuela Minerals Sector

April 8, 2026

Explaining OFAC Venezuela Mining Sector-Related General Licenses 51A, 54 and 55

Francisco Balduzzi, Julius Bodie, Alan Enslen, José Luis Vittor Womble Bond Dickinson + Follow Contact LinkedIn Facebook X Send Embed

On March 27, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License (GL) 51A, GL 54, and GL 55, each focused-on Venezuela’s minerals sector (including gold). Below a brief summary of the activities authorized under each GL.

GL 51A 1 authorizes, for an “established U.S. entity” 2 transactions ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin minerals (including gold), involving the Government of Venezuela, Minerven, or entities 50% or more owned by Minerven—provided that (a) the contract is governed by U.S. (or U.S. jurisdiction) law with U.S. dispute resolution, and (b) any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds, or any other account as instructed by the U.S. Department of the Treasury.

Below and illustrative summary of authorized activities under GL 51A include:

• Commercial, legal, technical, safety, and environmental due diligence and assessments ordinarily incident to the authorized trade.
• Shipping/logistics and related services, including chartering vessels, arranging security services, obtaining marine insurance and P&I coverage, and arranging port/terminal services (including with port authorities or terminal operators that are part of the Government of Venezuela).
• Processing or refining of Venezuelan-origin minerals, except to the extent restricted by the GL’s certain carve-outs. GL 54 authorizes the provision from the United States or by a U.S.-person of goods, technology, software, and services for minerals operations in Venezuela (including gold), involving the Government of Venezuela, Minerven, or Minerven-owned (50%+) entities, provided that (a) the contract is governed by U.S. (or U.S. jurisdiction) law with U.S. dispute resolution, and (b) any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds, or any other account as instructed by the U.S. Department of the Treasury.

Below and illustrative summary of authorized activities under GL 54:

• Associated transactions ordinarily incident and necessary to the above, including processing of payments and arranging shipping/logistics, chartering vessels, marine insurance and P&I coverage, and port/terminal services (including with Government of Venezuela port authorities/terminal operators).
• Maintenance of minerals operations in Venezuela, including refurbishment or repair of items used for minerals activities. GL 55 authorizes transactions related to negotiating and entering “contingent contracts” for new investment in Venezuela’s minerals sector (including gold). Performance of any such contract must be expressly contingent on separate OFAC authorization; in other words, GL 55 generally permits deal talks and signing, but not implementation absent further authorization.

Below and illustrative summary of authorized activities under GL 54:

• Negotiating and entering into contingent contracts (e.g., agreements in principle, pro forma/executory agreements, bids/proposals in response to public tenders, binding MOUs, and similar instruments) for new investment in Venezuela’s minerals sector.
• Negotiating/signing contingent contracts to (i) engage in new exploration, development, mining, extraction, processing, refining, or production activities; (ii) expand existing minerals operations in Venezuela; and/or (iii) form new joint ventures or other entities in Venezuela related to those activities—provided performance is contingent on separate OFAC authorization.
• Prefatory steps for the above negotiations, including commercial, legal, technical, safety, and environmental due diligence and assessments. The following chart provides examples of activities that are not permitted under General Licenses 51A, 54, and 55:

1 GL 51A replaced and superseded in its entirety GL 51 dated March 6, 2026, which authorized established US Entities to import Venezuelan origin gold into the United States and certain ancillary activities under certain conditions. GL51A expands the scope of GL51 (i) to the entire mineral sector (including gold), and allows (iii) importation, refining, resale, or exportation beyond the United States and to other countries.

2 Means any entity organized under the laws of the USA or any jurisdiction within the USA on or before January 29, 2025.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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