On April 19, 2021, the Office of Foreign Assets Control (“OFAC”) issued Belarus General License 2H (“GL 2H”) revoking General License 2G (“GL 2G”), which was due to expire on April 25, 2021.

For more than five years, OFAC regularly extended GL 2 G, and earlier versions of it, authorizing U.S. person activity with the following nine sanctioned Belarusian companies:

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

The new GL 2H will end this authorization, allowing only a 45-day wind down period for transactions “ordinarily incident and necessary to the wind down” of transactions involving these nine entities and entities in which they own a 50 percent or greater interest.  The wind down ends at 12:01 a.m. eastern daylight time on June 3, 2021.

The general license does not authorize the unblocking of property, nor transactions or activities that are otherwise prohibited.  Authorized transactions of more than $50,000 by U.S. persons must be reported to the State Department.

Thus far, these actions are U.S. only.  There has been media speculation that the E.U. or U.K. might take similar actions, but to date they have not yet announced any actions.