Today, OFAC issued a general license authorizing U.S. persons to engage in transactions with certain Belarus-based companies that have been designated as Specially Designated Nationals (SDNs). Specifically, the general license authorizes transactions with the following companies:
- Belarusian Oil Trade House
- Belneftekhim USA, Inc.
- Belshina OAO
- Grodno Azot OAO
- Grodno Khimvolokno OAO
- Lakokraska OAO
- Naftan OAO
- Polotsk Steklovolokno OAO
Additionally, the general license authorizes transactions with entities owned 50 percent or greater by the entities listed above.
The general license is subject to three conditions worth noting:
- The authorization is in effect until April 30, 2016, at which point it will terminate unless extended.
- The entities will remain listed as SDNs, and property of the listed entities and their subsidiaries that was blocked before October 30, 2015 remains blocked. For example, if a U.S. bank previously blocked the funds of one of the listed entities, those funds remain blocked.
- U.S. persons that engage in transactions authorized by the general license are required to submit a report to the State Department where a transaction or series of transactions exceeds $10,000.
Also today, the European Union announced that it would suspend sanctions against Belarus for four months.
The U.S. and EU measures follow the October 11 reelection of Alexander Lukashenko as President of Belarus. Before the election, the Lukashenko government welcomed international election monitors and freed certain political prisoners. These developments, along with today’s easing of sanctions, could mark a turning point in relations between Belarus and the West, although that remains to be seen.
In the coming days, Steptoe will issue an international law advisory providing further detail regarding the easing of sanctions against Belarus. You can sign up for the international law advisory here.