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OFFICE OF FOREIGN ASSETS CONTROL
Venezuela Sanctions Regulations
31 CFR part 591
GENERAL LICENSE NO. 55A
Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Coal or Minerals Sectors
(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, including Carbones del Zulia S.A., 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, that are related to the negotiation of and entry into contingent contracts for new investment in the coal or minerals sectors of Venezuela, including the gold sector of Venezuela, are authorized, provided that the performance of any such contract is made...
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Venezuela Venezuela General License 51A broadly authorizes transactions “ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin minerals, including gold”. This excludes “[e]xploration, development, mining, extraction, processing, refining, or production of minerals in Venezuela or the formation of joint ventures or other entities in Venezuela to engage in” such activities.
GL 54, similar to the “oil, gas, or petrochemical products”-related GL 48, authorizes transactions “ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development” of the relevant sectors. The carveouts to the two GLs are substantively identical as well. See comments to Venezuela General...