Venezuelan gold in the US: OFAC lets it be refined, but who vouches for its origin?

The gold Minerven sells to Trafigura leaves El Callao half-finished, as doré bars that are not yet bullion. To become bullion it has to pass through a refinery that melts it, purifies it and puts its name behind the metal's origin.

That signature is what is missing.

On September 28 an investigation was published, resting on three sources who do not give their names, saying that the gold Trafigura has imported since March, worth hundreds of millions of dollars, is sitting in US warehouses with no buyer. Neither Trafigura, nor Minerven, nor the Venezuelan government has confirmed it. Trafigura did say its supply-chain review has not finished, and that its auditor has so far found no illegal actors at the mines.

If the report is confirmed, the blockage is not where people usually look when sanctions come up. Washington has spent six months clearing obstacles for this gold, version after version of the same license, and the one left is set by a refiner.

Six months of license

We set the five versions side by side. The first, of March 6, was narrow: gold and nothing else, to be imported into the United States, refined there and resold from there, with the contract under US law. Each replacement loosened something, and the most important came three weeks later, when 51A stopped requiring the metal to pass through the United States.

Two conditions stayed intact in all five. Whatever is paid to Minerven, which remains on the sanctions list, goes into accounts the Treasury holds and whose destination the State Department decides. And whoever buys or sells Venezuelan gold sends Washington, every thirty days, the documentation tracing the chain of custody, in a report nobody publishes.

Trafigura's contract dates from the same week. It was signed on March 5, the day before the date of the first license, with the US Interior Secretary officiating, and the first gold took off hours later on a chartered plane. It is a prepayment contract that gives the trading house, for one year, the right to buy and export what the country's handful of underground mines produce. In March a volume of between 650 kilograms and one tonne was reported; what is reported now is that purchases can run as high as 400 kilograms a month.

For scale: 400 kilograms of fine gold would be worth about $53 million at the September 28 price. Doré carries less gold per kilogram, so that is a ceiling, and even so six months at that pace are enough to make the reported figure, hundreds of millions, plausible.

The signature

A refinery does two jobs. One is chemical. The other is vouching for what it melts, and that is where the problem lies. In London, which sets the standard for investment bullion, accredited refiners follow a responsible-sourcing guidance with external assurance, and starting with the reports they file this year they must publish, in a public annex, every country from which they receive mined material. Whoever takes Minerven's gold will have to write "Venezuela" on that list, in full view of its clients, its banks and its competitors.

At an industry gathering in London, an Asahi Refining executive put it out loud: "Do we want to be the first refiner to publicly announce that we are receiving Venezuelan gold?"

The question was not a technical one.

Trafigura tried to close that flank at the source. It buys only from two industrial mines, fenced off and guarded by the military, where gold is mined and smelted on site, and it hired an auditor in the spring and a risk consultant in the summer, by which time it had already bought uncertified gold.

The September 28 investigation holds that even that perimeter falls short: brigades working inside the fence hand part of what they dig to a local gang and part to Minerven, which melts it together with Trafigura's gold. Its own consultant acknowledged that building a supply chain in Venezuela free of that exploitation is very hard.

Who carries the gold

The money has already moved. Because the contract is a prepayment, the trading house paid up front, and what was owed to Minerven went — as the license requires — into the Treasury accounts, where it stays until the State Department decides. If the metal finds no refiner, Trafigura is the one carrying it, and on September 28 it was carrying it with the ounce at its lowest since August 5.

For Venezuela, the risk lies in the next contract.

Trafigura's right lasts one year and others are coming behind it: on September 16 Heeney Capital signed a thirty-year concession over the Chocó mine, an open pit, with Mercuria as partner, and the two reckon their agreements could one day move $2.2 billion a year in minerals. What else weighs on that mine besides the contract is in our El Callao analysis. In May, the mining development minister put 2026 output at some twelve tonnes, against 9.5 in 2025, already the largest official output since 2008.

If gold from two fenced mines visited by an auditor cannot find anyone to sign for it, gold from an open-pit mine will find it harder. The licenses have given almost everything they could give; what is missing is decided in the annex of an annual report.

What would move the math

Nothing that would change this reading runs through the Treasury. The first refiner to take the gold will have to say so in its report, so whoever receives Venezuelan metal this year will make it public in 2027. A sale outside the London circuit, which the license allows in almost any country, would show what price an origin nobody signs for can fetch. And in March Trafigura's contract turns one: if it reaches that date with no refiner, it will be renewed, or not, over gold the market has not yet accepted.