On April 19, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 2H under the Belarus Sanctions Regulations, representing a shift in the licensing policy for transactions with certain entities. Since October 2015, now revoked OFAC General License No. 2G had authorized transactions with these nine companies. The new General License 2H essentially requires the winding down of any transactions with the entities and authorizes until June 3, 2021 all transactions and activities “ordinarily incident and necessary” to winding down activities. U.S. persons and companies now have 45 days to wind down transactions and activities with the following entities:
- Belarusian Oil Trade House
- Belneftekhim
- Belneftekhim USA, Inc.
- Belshina OAO
- Grodno Azot OAO
- Grodno Khimvolokno OAO
- Lakokraska OAO
- Naftan OAO
- Polotsk Steklovolokno OAO
This authorization includes any entities that are 50% or greater owned or controlled by these listed entities. This general license does not authorize the unblocking of any specifically sanctioned and blocked property or any other activities prohibited under the Belarus Sanctions Regulations. OFAC notes that for any wind down transactions in excess of $50,000, U.S. persons must report such transactions to the Department of State no later than 30 days after execution of the transaction.
The Belarus sanctions were implemented during the presidency of George W. Bush and are intended to sanction persons and entities determined by the United States to have undermined or continue to undermine Belarus’s democratic processes or institutions.