OFAC Authorizes Venezuelan-Origin Gold Transactions Following Export Deal

On March 6, 2026, OFAC issued Venezuela Sanctions Regulations General License (“GL”) 51 (available here), authorizing certain transactions related to the exportation of Venezuelan-origin gold to the United States.  GL 51 follows reports that the U.S. government brokered a deal for Venezuela’s state-owned mining company, CVG Compania General de Mineria de Venezuela CA (“Minerven”), to export gold to the U.S. market.

GL 51 authorizes all transactions, including with the government of Venezuela, Minerven, and entities owned, directly or indirectly, 50 percent or more by Minerven (“Minerven Entities”), 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, the refining of such gold in the United States, and the resale or exportation of such gold from the United States.  As with other recent Venezuela-related GLs, GL 51 is subject to several notable restrictions, including:

• Only “established U.S. entit[ies],” meaning entities organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025, may rely on GL 51;

• Any contracts with the government of Venezuela, Minerven, or Minerven Entities for transactions authorized by GL 51 must include U.S. choice-of-law and forum selection clauses;

• Other than local taxes, permits, and fees, sanctioned-person payments must be routed to the Executive Order 14373 U.S. government-controlled account;

• Payment terms for transactions authorized by GL 51 must be “commercially reasonable,” and payments cannot be made in any digital currency associated with the government of Venezuela;

• Transactions with persons located in or organized under the laws of Russia, Iran, North Korea, or Cuba (or persons that are owned, controlled, or in a joint venture with such persons), and with persons located in or organized under the laws of Venezuela or the United States that are owned, controlled, or in a joint venture with persons located in or organized under the laws of China, remain prohibited; and

• GL 51 imposes a reporting requirement on persons who rely on it.

Together with OFAC’s previous Venezuelan-origin oil-related GLs, GL 51 reflects a further opening of Venezuela for U.S. business following the United States’s capture of Nicolás Maduro in January 2026.  U.S. companies interested in Venezuelan-origin gold transactions should carefully review GL 51’s requirements, including the “established U.S. entity” limitation, payment restrictions, and reporting obligations.