" grz was NEVER legally in the position to begin mining operations"

Absolutely correct; there is a sequence of permits and actions which is required before actual full scale mining can take place. There is a sequence of permits required by MIBAM and a different sequence required by MinAmb.

As far as I can determine both KRY and GRZ have all permits and approvals from MIBAM that they require at this stage and they are both in good standing.

For MinAmb, first there needs to be an approved Environmental and Social Impact Study, which GRZ has received from MinAmb and that is followed by the Authorization to Affect which is required before construction can commence. GRZ did have this permit but it was revoked by Ortega.

However, even after the issuance of the Authorization to Effect, there needs to be an "Initiation Act". This isn't an actual permit as no input is required from the company. It's just an administrative document formally allowing work to commence. GRZ was never given that document even though there are no actual requirements to be completed in order to get it.

Even when construction has been completed there is a final permit before minerals can be mined and extracted as well as numerous small permits for things like use of explosives, water use and disposal etc.

Don't be fooled into thinking that when KRY gets their next permit that's the end of the saga. Hopefully the wheels will be greased by then to allow the Venezuelan government to actually want to expediate the process, but past experience doesn't indicate that, and even now things continue to drag on.

Remember the Goldfields eventually got forced out of the Bolivar mine because of a minor water use permit which was denied for years. If somebody in the system thinks they can either screw a dollar out of their delay or just wants to be bloody minded, they seem to be able to do so with impunity.