Venezuela's Mining Sector Opens to US Commerce: What OFAC General License 51 Means for Strategic Minerals

Context

On 6 March 2026, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License No. 51, "Authorizing Certain Activities Involving Venezuelan-Origin Gold," a measure that begins to reopen Venezuela's mining sector to regulated US commercial activity. The licence was signed by OFAC Director Bradley T. Smith under the Venezuela Sanctions Regulations, 31 CFR part 591. It is the first general licence under the Venezuela sanctions framework focused specifically on the commercial trade of Venezuelan gold, and it arrived one day after US Interior Secretary Doug Burgum concluded a two-day visit to Caracas during which he met acting President Delcy Rodríguez alongside more than two dozen US mining and minerals companies.

The licence is narrow in what it authorises and precise in what it excludes. Understanding both is essential to assessing what the licence represents in practice and what may follow.

What GL 51 authorises

GL 51 permits established US entities—defined as those incorporated under US law on or before 29 January 2025—to engage in transactions ordinarily incident and necessary to the exportation, sale, supply, storage, purchase, delivery and transportation of Venezuelan-origin gold for importation into the United States, the refining of that gold in the United States, and its resale or re-exportation from the United States. These activities are authorised even where they involve the Government of Venezuela, Minerven (CVG Compañía General de Minería de Venezuela CA), or entities in which Minerven holds a 50 per cent or greater interest.

Several ancillary activities are also covered: commercial, legal, technical, safety and environmental due diligence; shipping, logistics, chartering of vessels; security services; marine insurance; and port and terminal services, including with Venezuelan government-linked port authorities. Any monetary payments to blocked persons, excluding local taxes, permits and fees, must be deposited into Foreign Government Deposit Funds as specified in Executive Order 14373 of 9 January 2026. All contracts with Venezuelan government counterparties must be governed by US law with US-based dispute resolution.

Reporting obligations are substantial: any party transacting under GL 51 must file a detailed report to the addresses specified in GL 51, including the State Department address listed in the licence, within ten days of the first transaction and every thirty days thereafter. The report must cover the parties involved, supply chain due diligence, quantities, prices, transaction dates, and payments to the Venezuelan government.

What GL 51 does not authorise

The exclusions are as analytically significant as the authorisations. GL 51 expressly prohibits: mining, exploration, production or refining of gold in Venezuela; the formation of joint ventures or other entities in Venezuela for those purposes; transactions involving entities linked to Russia, Iran, North Korea, Cuba, or China; payment terms that are not commercially reasonable, involve debt swaps, or are denominated in Venezuelan digital currency; transactions involving blocked vessels; and the unblocking of any property blocked under the Venezuela Sanctions Regulations.

GL 51 is therefore best understood as a commercial access licence. It opens the door to US participation in the trade of Venezuelan gold that is already produced or can be produced by existing Venezuelan operations. It does not permit US companies to invest in, develop or operate gold mines in Venezuela under its terms.

The proximate trigger: the Burgum visit

The timing of GL 51 reflects the rapid sequencing of US engagement with Venezuela's natural resources sector following the capture of Nicolás Maduro by US forces on 3 January 2026. Burgum, who leads the US National Energy Dominance Council, arrived in Caracas on 4 March with a delegation of over two dozen US mining and minerals companies. He met with Rodríguez at the Miraflores presidential palace and, according to Reuters, also convened sessions with executives from foreign mining companies and, on 5 March, with major foreign oil and gas companies and Venezuelan corporate and banking leaders.

Rodríguez announced at the joint press engagement with Burgum that a reform of Venezuela's 1999 mining law would be submitted to the National Assembly within days. The draft has not been made public, but according to Reuters, it is expected to cover gold, diamonds and rare earths, and is likely to pass given the ruling party's control of the legislature. Rodríguez described the oil reform passed in January—which reduced taxes, expanded ministerial authority and granted autonomy to private producers—as the model for the forthcoming mining legislation.

E&E News reported, citing a White House official, that the visit sealed a deal for Minerven to sell gold to global commodity trader Trafigura. GL 51 was the regulatory instrument issued within twenty-four hours to operationalise that commercial arrangement. Burgum also stated explicitly that further general licences for the mining sector, comparable to those already issued for oil producers, are forthcoming.

The sequencing logic: mining follows oil

To assess what may follow GL 51, the oil sector trajectory since January 2026 is instructive. Following Maduro's removal, OFAC issued a structured series of general licences expanding permitted activity in stages: GL 46 authorised Venezuelan oil trading and midstream and downstream activities; GL 46A amended it to allow local tax and fee payments to the Venezuelan government; GL 47 authorised sales of US-origin diluents to Venezuela; GL 48 authorised goods, services, technology and software for oil exploration, development and production; GL 49 authorised the negotiation and execution of contingent investment contracts; and GL 50 (later amended as GL 50A) granted broad operational authorisation to specified oil companies and their subsidiaries.

That progression moved from commercial access through operational enablement to investment authorisation, with each step conditioned on verified compliance from the Rodríguez government. GL 51 positions mining at the equivalent of GL 46: the first commercial gateway, issued in response to a concrete diplomatic and commercial agreement, with further licences explicitly flagged as forthcoming.

If the oil analogue holds, the next steps would be licences authorising goods and services for Venezuelan mining operations, followed by authorisation to negotiate investment contracts, and ultimately operational licences for named companies. The forthcoming mining law reform would provide the domestic legal foundation on which those licences could be layered.

Venezuela's mining sector: the resource opportunity and its constraints

Structural Geological Map of Venezuela. Source: Sociedad Venezolana de Geólogos.

The scale of Venezuela's mining endowment in the Arco Minero del Orinoco is potentially significant, although much of the reserve base remains unverified. The Arco Minero, designated as a National Strategic Development Zone by decree in February 2016, covers approximately 111,843 km²—roughly 12 per cent of Venezuelan territory—and encompasses parts of Bolivar, Amazonas and Delta Amacuro states. Venezuelan government estimates—widely cited but not independently verified—have suggested that potential gold deposits could reach several thousand tonnes, which, if confirmed, would place Venezuela among the world's largest gold endowments. The region also contains coltan, bauxite, industrial diamonds and iron ore. On rare earths, Reuters noted following the Burgum visit that exploration has not yet taken place in Venezuela to confirm reserves, meaning that the rare earth potential, though associated with the Guiana Shield geological formation, remains speculative at this stage.

Several structural constraints are material. First, Venezuela's industrial mining infrastructure is severely degraded following years of underinvestment, nationalisation and sanctions. According to Reuters, plants urgently need major repairs and investment for expansions and upgrades, and some experts have warned that the capital requirement for mining development may exceed even that needed for the oil sector. Second, the Arco Minero has been extensively documented as a zone of illegal mining, armed group control, and serious human rights abuses. The Venezuelan armed forces and state entities, including Minerven and the military mining company CAMIMPEG, have historically operated alongside rather than in opposition to informal and criminal extraction. Any formalisation of the sector will require addressing these conditions, not merely passing new legislation. Third, Venezuela's mining sector carries significant outstanding legal liabilities: the country owes substantial sums to Crystallex, Gold Reserve and Rusoro Mining, among others, from nationalisation-era disputes that have not been resolved.

Fourth, the explicit exclusion of Chinese-linked entities from GL 51 is a structural feature of US policy design, not an incidental compliance provision. China has been the primary commercial partner for Venezuelan gold exports in recent years, largely through state-linked intermediaries. Redirecting those flows to US-controlled channels is a deliberate geopolitical objective, framed by the Trump administration in the context of its broader effort to diversify critical mineral supply chains away from Chinese dominance.

Implications

For companies, GL 51 creates a narrow but real commercial opening: US-incorporated entities with existing or potential access to Venezuelan gold can now structure trading arrangements with Minerven, subject to robust due diligence and reporting requirements. The Minerven-Trafigura deal illustrates the immediate commercial application. The exclusion of Chinese-linked entities and the US-law contract requirement will shape counterparty selection in ways that have broader market implications.

For investors and financiers, the more consequential question is whether investment-level licences follow the pattern established in oil. Burgum's public statement that such licences are forthcoming is the clearest available signal, but the timeline and conditionality are not yet defined, and will likely depend on progress in passing the new mining law and the broader stability of the US-Venezuela arrangement.

For policymakers and analysts, GL 51 confirms that the Trump administration's approach to Venezuela extends beyond oil and is being designed with deliberate sectoral sequencing. Mining is the second front, opened with a commercial access licence and a diplomatic visit structured to build investor confidence, consistent with the administration's wider critical minerals agenda.

The strategic minerals dimension deserves particular attention. GL 51 is framed around gold, which is the only commodity currently producible at scale in Venezuela without major new investment. However, the policy architecture being constructed points toward a broader objective. The forthcoming mining law is expected to cover rare earths and other strategic minerals alongside gold and diamonds. Venezuela's Arco Minero contains deposits of coltan, bauxite and iron ore, and the Guiana Shield geological formation is associated with rare earth potential that has not yet been subject to independent exploration. Gold is the entry point, but the regulatory sequencing, if it follows the oil precedent, is designed to open the door to strategic minerals investment over time.

One structural uncertainty cuts across all three audiences. The investment sequencing described above is contingent on the durability of the current US-Venezuela arrangement, which remains politically fragile. Rodríguez governs without a democratic mandate, under US sanctions that have not been lifted, and Reuters reported on 4 March that the Trump administration has been applying pressure on her government through the threat of legal proceedings. The pace and scope of further sanctions relief will reflect geopolitical calculations that go beyond the mining sector itself, and could be reversed or suspended if the political dynamic shifts. Participants in this market should treat the oil sequencing analogy as a structural guide, not a guarantee.

The opportunity in Venezuela's mining sector is substantial in geological terms. The conditions under which it can be responsibly and commercially realised remain complex, and the regulatory architecture needed to support investment-level engagement is still being assembled. GL 51 is a significant first step. It is not yet the opening of the sector.

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Organisations seeking to translate these dynamics into an actionable strategy, whether to advance specific projects, to inform policy design, to structure investments, or to navigate regulatory and financing pathways across jurisdictions, are invited to contact AAP Consulting for further discussion.

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