Venezuela-related General License 51A, "Authorizing Certain Activities Involving Venezuelan-Origin Gold."

Date issued: Mar. 07 2026

Last substantive commentary amendment:
Mar. 28 2026

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TURBOFAC Commentary (486 words)

Notes:

[3-27-26 Update - GL reissued as GL 51A to (i)add “reexportation” and “resale” to the scope of authorized activities, (ii) change “gold” to “minerals, including gold,” (iii) remove requirements that goods be imported into the United States, (iv) add a carveout for any “transaction involving the processing or refining of Venezuelan-origin minerals, including gold, in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or the People’s Republic of China,” and adding “exploration,” “development” and “processing” to the list of excluded activities.

The amended GL also adds an interpretive “Note 3 to Paragraph” specifying that “processing or refining” covered minerals falls within the scope of transactions “ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, purchase, delivery, or transportation of” such minerals. See also