On 29 October 2015, OFAC issued General License No. 2 under the Belarus Sanctions Regulations to authorise US persons to engage in all transactions with nine specified entities that were blocked under the Belarus sanctions regime, as well as entities that are deemed to be blocked because they are 50% or more owned by one or more of the specified entities. However, the licence only authorises transactions until 30 April 2016, and it does not unblock any previously blocked property.
The temporarily unblocked entities are mainly in the energy and industrial manufacturing fields. They are Belarusian Oil Trade House, Belneftekhim, Belneftekhim USA, Belshina, Grodno Azot, Grodno Khimvolokno, Lakokraska, Naftan, and Polotsk Steklovolokno. By the terms of the licence, however, transactions with these entities exceeding $10,000 must be reported within 15 days to the US State Department’s Office of Eastern European Affairs. In addition, records of any transactions with those entities must be kept for at least five years.
The new US general licence coincides with the European Union’s decision to suspend Belarus sanctions for four months, but unlike the recent EU decision, it applies only to the specified entities. Transactions involving other entities or individuals on the Specially Designated Nationals (SDN) List, or entities 50% or more owned by them, remain prohibited.