On March 6, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continued its trend of selectively easing the Venezuela sanctions by (1) issuing General License No. 51 (“GL 51”), the first general license (“GL”) beyond the energy sector, and (2) publishing six new Frequently Asked Questions (“FAQs”) addressing the scope of several of the previously issued energy-related GLs. In parallel, Venezuela has begun reforming its mining sector.
Background
Since late January, OFAC has issued a flurry of GLs relaxing the sanctions on Venezuela’s oil and gas sector, including the Government of Venezuela (“GOV”) and Petróleos de Venezuela, S.A. (“PdVSA”). These GLs authorize a broad range of activities related to the exploration, development and production of oil and gas as well as the sale, export and transport of oil. We have previously written about these licenses, here, here, here, and here. Until now, there has been no broader relaxation of sanctions and export controls, and all GLs have focused on the energy sector.
Mining Sector
- General License No. 51
GL 51 authorizes all transactions that are ordinarily incident and necessary to the exportation, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin gold for importation into the United States, including the refining of such gold in the United States, resale or exportation of such gold from the United States by an established US entity.
GL 51 does not include authorization for mining, exploration, production, or refining of gold in Venezuela. Nor does it authorize the formation of joint ventures or other entities in Venezuela to engage in GL 51 authorized activities. The energy sector GLs started off narrowly focused on trading and subsequently expanded to upstream and downstream activities, so we could see a similar trajectory for the gold sector.
Transactions involving the following US-sanctioned parties are authorized:
- The GOV;
- CVG Compania General de Mineria de Venezuela CA (“Minerven”), Venezuela’s state-owned mining company; or
- Any entity in which Minerven owns, directly or indirectly, a 50% or greater interest (“Minerven Entities”).
GL 51 also authorizes commercial, legal, technical, safety, and environmental due diligence, as well as shipping, logistics, insurance, security, and port‑related services that are ordinarily incident to the covered gold transactions. The issuance of GL 51 coincided with the announcement of an agreement between Minerven and Trafigura for the sale of up to 1,000 kilograms of gold doré bars, to be shipped to US refineries.
This GL has a number of conditions and restrictions:
- Requirements related to contractual safeguards, payment terms, and reporting requirements, which are similar to those found in the energy GLs.
- Only an “established US entity” may rely on GL 51, which is defined as an entity organized under US law on or before January 29, 2025, as is the case for GL 46A.
- Except for local taxes, permits, or fees, monetary payments to the GOV, Minerven, or Minerven Entities must be made into the Foreign Government Deposit Funds accounts established pursuant to Executive Order 14373 or another account designated by the US Department of the Treasury.
- Venezuela’s Mining Sector Reforms
Coinciding with the issuance of GL 51, there have been several developments in the Venezuelan mining sector. On March 9, 2026, the Venezuelan National Assembly approved in first discussion the Bill of Organic Mining Law, which intends to repeal and replace the 1999 Mining Law and introduce other changes to attract national and international investments. This proposal has now entered into the consultation phase, whereby the legislation will be submitted for the second and final discussion and approval by the Venezuelan National Assembly.
As a preliminary step in connection with these reform efforts, on March 6, 2026, pursuant to Presidential Decree N° 5,266 (the “Decree”) published in the Special Official Gazette N° 6,994, the GOV ordered the merger of Corporacion Venezolana de Mineria (“CVM”) with Minerven. Accordingly, CVM will assume Minverven’s rights, assets and obligations, and Minerven will cease to exist. CVM, in turn, will have a 30 day term, computed as of the date of the Decree, to make all organizational changes required in the field of human talent related to the merger. This term may be extended for another 30 days by the Ministry of the People’s Power for Ecological Mining Development and Basic Industries. Finally, the amendment of CVM’s by-laws is also authorized, in order to adopt all adjustments necessary as a result of this merger.
New FAQs on Energy-Related General Licenses
OFAC issued six FAQs providing guidance on the scope of GLs 46A, 47, 48, 49, and 50A. Some of the highlights are:
- FAQ 1239 explains how to obtain payment account information for the Foreign Government Deposit Funds accounts used for payments required under GL 46A, GL 48, and GL 50A. This applies to any monetary payments to the GOV or PdVSA, excluding payments for local taxes, permits, or fees. This is also relevant to new GL 51 discussed above.
- FAQ 1241 provides examples of a broad range of activities authorized for both oil majors and oilfield service provides under GL 48, including maintenance, refurbishment, or repair of items used for oil or gas exploration, development, or production activities; spare or replacement parts required to maintain oil or gas production activities; exploration and subsurface interpretation software; and well stimulation products such as fracturing fluids.
- FAQ 1243 states that entities not identified in the Annex to GL 50A (i.e., those that are not BP PLC, Chevron Corporation, Eni S.p.A., Établissements Maurel & Prom SA, Repsol S.A., and Shell PLC) can rely on other authorizations to support the development of oil or gas projects in Venezuela. For example, GL 49 allows companies to enter into contingent contracts for new investments in Venezuela, subject to obtaining a separate OFAC specific license before performance can begin. FAQ 1243 also confirms that US persons may enter contracts with entities listed in the GL 50A Annex to support authorized activities in the Venezuela oil or gas sectors.
As US policy regarding Venezuela continues to develop, OFAC may issue new or expanded general licenses that go beyond those discussed above or issue more public guidance. We are closely monitoring these developments and will continue to update this blog as and when new actions are taken. Please visit our Venezuela Brief for the latest insights and resources.
