On October 30, 2015, OFAC issued a temporary general license, valid through April 30, 2016, permitting certain transactions with nine Belarusian entities on the SDN list, including Belneftekhim, a petroleum and chemical company, and eight related companies. Belneftekhim was originally placed on OFAC’s SDN list in 2006 for being controlled by an SDN, Belarusian President Alexander Lukashenko. The U.S. Department of State explained that that the temporary relief was in response to the Belarusian government’s August 2015 release of six political prisoners.
Under the general license, blocked property and interests in property of the nine companies remain blocked, and U.S. persons conducting any transaction valued more than US $10,000 must file a report with the U.S. Department of State within fifteen days of executing the transaction. U.S. persons should be cautious in using the general license and consider whether sanctioned persons not subject to the license may be conducting transactions through the nine entities. In parallel with this U.S. temporary relief, the EU announced a temporary lifting of sanctions on Belarus, which included removal of the asset freeze and travel ban on President Lukashenko. Under the EU policy, the sanctions will be dropped if they are not reimposed by the EU’s 28 members at the end of this period.