Navigating the Office of Foreign Access Control’s Latest Guidance on Venezuela’s Minerals Sector

On March 27, 2026, the Office of Foreign Access Control issued three new general licenses focused on Venezuela’s minerals sector, including gold. In today’s episode, we break down what each license authorizes, the conditions that apply, and how they differ in scope. From trade in Venezuelan-origin minerals, to operational support, to contingent contracts for new investment, we explore what these licenses permit, and what they still leave off-limits.

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

About the Authors

• José Luis Vittor*
• Alan F. Enslen
• Francisco Balduzzi*
• Julius H. Bodie

Transcript

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On March 27, 2026, the Treasury Department’s Office of Foreign Assets Control issued three new general licenses focused on Venezuela’s minerals sector. These licenses—GL 51A, GL 54, and GL 55—address a range of activities involving Venezuelan-origin minerals, including gold. Together, they provide updated guidance on what is and is not permitted under U.S. sanctions.

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Each license serves a different purpose, and understanding the distinctions matters. The licenses don’t remove sanctions wholesale, but they do authorize specific activities under defined conditions. Let’s walk through what each one allows, starting with General License 51A.

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GL 51A authorizes certain transactions by what the Office of Foreign Assets Control calls an “established U.S. entity.” These transactions must be ordinarily incident and necessary to activities like exporting, selling, purchasing, transporting, or storing Venezuelan-origin minerals. Importantly, the transactions may involve the Government of Venezuela or Minerven and its majority-owned entities.

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But that authorization comes with conditions. The underlying contract must be governed by U.S. law or another U.S. jurisdiction framework, with U.S.-based dispute resolution. And most payments to blocked persons must be routed into specific Treasury-designated accounts, excluding certain local taxes and fees.

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The Office of Foreign Assets Control also provides examples of what activities GL 51A is meant to cover. That includes commercial, legal, technical, safety, and environmental due diligence tied to the authorized trade.

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Shipping and logistics services are also included, such as chartering vessels, arranging security, and obtaining marine insurance. Processing or refining of Venezuelan-origin minerals may be permitted as well, though the license includes specific carve-outs that still apply.

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General License 54 moves the focus from trade in minerals to support for minerals operations. It authorizes U.S. persons to provide goods, technology, software, and services for minerals operations in Venezuela, again including gold.

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Like 51A, GL 54 applies to activities involving the Government of Venezuela, Minerven, or Minerven-owned entities. The same contract and payment conditions apply, reinforcing that these authorizations operate within a controlled framework.

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The illustrative activities under GL 54 include transactions ordinarily incident to providing those goods and services. That means payment processing, shipping logistics, marine insurance, and port or terminal services may all be covered.

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GL 54 also authorizes maintenance-related activity. Refurbishment or repair of items used for minerals operations in Venezuela falls within the scope of the license, provided the other conditions are satisfied.

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General License 55 takes a different approach. Rather than authorizing operations or trade, it allows parties to negotiate and enter into “contingent contracts” for new investment in Venezuela’s minerals sector.

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The key word there is “contingent.” Performance of any such contract must be expressly conditioned on receiving separate Office of Foreign Assets Control authorization. In other words, deal talks and signing may proceed, but implementation cannot without further approval.

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The license identifies several types of permitted agreements, including agreements in principle, memoranda of understanding, bids, and proposals. These may relate to new exploration, expanded operations, or forming new joint ventures tied to minerals activities.

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General License 55 also allows introductory steps for those negotiations. That includes commercial, legal, technical, safety, and environmental due diligence conducted in anticipation of a potential investment.

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But not everything is authorized under these licenses. The Office of Foreign Assets Control provided a summary chart outlining activities that remain prohibited under these General Licenses.

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That reminder is important. While the licenses open certain doors, they do not eliminate all restrictions. Careful analysis is still required to stay within authorized bounds.

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The bottom line is that these general licenses provide targeted authorization, not blanket permission. Each one has a defined scope and specific conditions that must be met.

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For companies looking at Venezuela’s minerals sector, understanding those contours is critical—and questions should be addressed with experienced sanctions counsel before moving forward.

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