The U.S. Treasury Department’s Office of Foreign Assets Control issued General Licenses 51D, 54C, and 55A on Wednesday, September 2, substantially modifying the scope of sanctions applicable to the coal and minerals industry in Venezuela, including gold.
These regulations allow for commercial operations, service provision, and international investments by US entities in key state-owned companies such as Carbones del Zulia and CVG Compañía General de Minería de Venezuela. This opens a window for the sector's operational reactivation under strict regulatory controls.
Economic and operational scope of licenses
License 51D authorizes the execution of export, re-export, purchase, sale, transport and refining activities of coal and minerals of Venezuelan origin, establishing as a financial condition that all monetary payments destined for blocked persons or state entities be deposited in Foreign Government Deposit Funds to avoid direct transfers without supervision.
Additionally, it imposes the strict obligation to resolve any commercial disputes or arbitrations in courts in the United States, the United Kingdom, France, or Singapore. For its part, LG 54C authorizes the provision of goods, services, technology, software, and preventive maintenance or repair of equipment necessary for mineral exploration and processing, subject to the mandatory submission of quarterly reports to the Department of State and the Department of the Interior detailing volumes, amounts, and taxes paid.
Finally, LG 55A allows the negotiation of letters of intent, memoranda of understanding, and tender offers for future investments or joint ventures, conditioning the execution of any new project on an additional specific authorization from OFAC.
Geopolitical limitations and financial restrictions
Despite the operational opening decreed for the Venezuelan mining sector, the US administration maintains marked limitations intended to contain the influence of non-aligned nations and block opaque payment schemes.
The licenses explicitly prohibit any transaction, corporate alliance, or refining process that directly or indirectly involves individuals, companies, or governments from Russia, Iran, North Korea, Cuba, and China.
Likewise, payments made through cryptocurrencies or tokens issued by the Venezuelan State are strictly restricted, as are debt swaps or transactions carried out under the modality of payments in kind, thus protecting financial control under the parameters required by Washington.
