GL-51A

Summary

General License No. 51A authorizes established U.S. entities (organized on or before January 29, 2025) to engage in transactions otherwise prohibited by the Venezuela Sanctions Regulations (31 CFR part 591) that are ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin minerals, including gold, even when such transactions involve the Government of Venezuela, Minerven, or Minerven Entities. Contracts with those parties must be governed by U.S. law and provide for U.S.-based dispute resolution. Monetary payments to blocked persons (other than local taxes, permits, or fees) must be directed to the Foreign Government Deposit Funds or another Treasury-designated account.

Authorized activities

• Exportation of Venezuelan-origin minerals, including gold
• Reexportation of Venezuelan-origin minerals, including gold
• Sale and resale of Venezuelan-origin minerals, including gold
• Supply and storage of Venezuelan-origin minerals, including gold
• Purchase of Venezuelan-origin minerals, including gold
• Delivery and transportation of Venezuelan-origin minerals, including gold
• Processing or refining of Venezuelan-origin minerals, including gold (subject to restrictions)
• Commercial, legal, technical, safety, and environmental due diligence and assessments
• Arranging shipping and logistics services, including chartering vessels
• Arranging security services
• Obtaining marine insurance and protection and indemnity (P&I) coverage
• Arranging port and terminal services, including with Government of Venezuela port authorities or terminal operators

Conditions

Contracts with the Government of Venezuela, Minerven, or Minerven Entities must specify U.S. governing law and U.S.-based dispute resolution. Monetary payments to blocked persons (excluding local taxes, permits, or fees) must go to the Foreign Government Deposit Funds per Executive Order 14373 or another Treasury-instructed account. The license does not authorize: commercially unreasonable payment terms, debt swaps, in-kind payments, or payments in Venezuelan digital currency (including the petro); transactions involving persons from Russia, Iran, North Korea, Cuba, or entities owned/controlled by such persons; transactions involving Venezuela- or U.S.-based entities owned/controlled by or in joint ventures with Chinese persons; processing or refining Venezuelan-origin minerals in Russia, Iran, North Korea, Cuba, or China; unblocking of VSR-blocked property; transactions involving blocked vessels; or exploration, development, mining, extraction, processing, refining, or production of minerals in Venezuela, or formation of joint ventures in Venezuela for such activities.

Reporting requirement

Any person that exports, reexports, sells, resells, purchases, or supplies Venezuelan-origin minerals (including gold) under this license must submit a detailed report to Sanctions_inbox@state.gov and ofac_intake@doi.gov identifying: (1) parties involved, (2) supply chain due diligence documentation, (3) quantities, descriptions, and purchase prices, (4) transaction dates, and (5) any taxes, fees, or payments to the Government of Venezuela. The first report is due within 10 days of the first such transaction, with subsequent reports every 30 days while transactions are ongoing.