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OFFICE OF FOREIGN ASSETS CONTROL
Venezuela Sanctions Regulations
31 CFR part 591
GENERAL LICENSE NO. 51
Authorizing Certain Activities Involving Venezuelan-Origin Gold
(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), including those involving the Government of Venezuela, CVG Compania General de Mineria de Venezuela CA (Minerven), or any entity in which Minerven owns, directly or indirectly, a 50 percent or greater interest (collectively, “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, by an established U.S. entity, are authorized, provided...
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1) This GL, which is modeled to an extent on the oil-related Venezuela General License 46A (see comments thereto), broadly authorizes 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, the refining of such gold in the United States, and the resale or exportation of such gold from the United States, by an established U.S. entity”. As with GL 46A, there are requirements that transactions be “established U.S. entity,” that payments to blocked persons be made into “Foreign Government Deposit Funds, as specified in Executive Order 14373,” and that contracts with GoV entities satisfy dispute resolution and choice of law requirements. See comments to GL 46A for discussion concerning those aspects of the GL, which are assumed to apply the same across...