On October 24, OFAC issued General License No. 2D renewing sanctions exemptions for nine Belarusian entities to make transactions otherwise prohibited by Executive Order 13405. Of note, the list of nine entities includes Belneftekhim (a/k/a The Belarusian State Concern for Oil and Chemistry). Belneftekhim manufactures chemical fertilizers and oil products and accounts for approximately 35% of Belarus’s exports and over 30% of the country’s industrial output.

General License No. 2D also authorizes transactions with any entities that are owned individually or in the aggregate, directly or indirectly, 50 percent or more by the nine entities. U.S. persons engaging in transactions involving, directly or indirectly, any of the nine entities are required, no later than 30 days after the execution of any such transaction in excess of $50,000, or any series of such transactions exceeding $50,000, to file a report with the U.S. Department of State, Office of Eastern European Affairs. Such reports shall include the following numbered sections and information: (1) Estimated or actual dollar value of the transaction(s), as determined by the value of the goods, services, or contract; (2) The parties involved; (3) The type and scope of activities conducted; and (4) The dates or duration of the activities.

General License No. 2D expires on April 30, 2018, unless extended or revoked. The general license has been biannually renewed, most recently on April 28, 2017.

Nine Belarusian Entities

  • Belarusian Oil Trade House
  • Belneftekhim
  • Belneftekhim USA, Inc.
  • Belshina OAO
  • Grodno Azot OAO
  • Grodno Khimvolokno OAO
  • Lakokraska OAO
  • Naftan OAO
  • Polotsk Steklovolokno OAO