On December 15, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Belarus General License 13, “Authorizing Transactions Involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, and Belaruskali OAO.” The general license authorizes all transactions prohibited by the Belarus Sanctions Regulations, 31 CFR part 548 (“BSR”), involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, Belaruskali OAO, and any entity in which one or more of these entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. However, the general license does not authorize the unblocking of any blocked property, nor does it permit transactions involving any other blocked persons under the BSR beyond the three specifically named entities and their majority-owned subsidiaries.

This development brings Belarus closer to Russia in terms of U.S. sanctions relief for exports of potash, a key input in fertilizers essential for global food production and crop yields. The significance of this action is amplified by the fact that Belaruskali is one of the largest state-owned companies in Belarus, making potash exports a meaningful source of revenue for the Belarusian regime.

This notable shift in U.S. sanctions policy toward Belarus contrasts sharply with the European Union (“EU”)’s approach to Belarusian potash and broader sanctions policy. The EU maintains comprehensive restrictions on imports of potash from Belarus under its sanctions framework targeting the Lukashenko regime, which were implemented following the 2020 presidential election and subsequent crackdown on political opposition. JSC Belarusian Potash Company and Belaruskali OAO (along with any entities they own or control) also remain sanctioned by the EU. While the EU has carved out certain humanitarian and agricultural exemptions in its Belarus sanctions program, potash imports remain generally restricted, creating a divergence between U.S. and EU sanctions policies on this commodity.

More recently, the EU broadened its Belarus sanctions regime this week by adding a new asset freezing designation criterion for individuals/entities who (i) plan, direct, engage in support or facilitate foreign information manipulation and interference; (ii) target the functioning of democratic institutions; (iii) enter an EU member state without authorisation; or (iv) interfere with, damage or destroy critical infrastructure. The EU has stated that this new criterion was linked to recent meteorological balloon incursions into Lithuania’s airspace, demonstrating a continued commitment from the EU to maintaining pressure on the Minsk regime.

It is also worth noting that potash was subject to the initial Trump tariffs earlier this year, specifically impacting Canadian and Mexican imports. According to U.S. Customs and Border Protection, these tariffs affected potash imports from North America, adding another layer of trade policy complexity to this critical agricultural input.

Crowell & Moring will continue to monitor developments related to Belarus sanctions and their potential impact to industry.

Tags: European Union, Sanctions, U.S. Department of Treasury
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Photo of Erik Woodhouse Erik Woodhouse

Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his

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Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his experience in private practice and in government at the Department of the Treasury and the Department of State.

Erik works with U.S. and foreign clients operating across borders on all aspects of these regimes, including developing and assessing compliance programs, advising on complex statutory and regulatory requirements, and leading companies through internal and government investigations. He has worked with major manufacturing and tech companies with global operations, multinational banks, investment funds and other financial services firms, and digital assets and virtual currency companies, collaborating with Crowell’s cross-disciplinary team that comprises former senior regulators, federal prosecutors, and in-house counsel.

Prior to joining Crowell, Erik served as Deputy Assistant Secretary of State for Counter Threat Finance and Sanctions at the Department of State, where he played a key role in the Department’s policy development and implementation related to all U.S. country-based sanctions programs and a range of global programs. Erik worked with counterparts across the executive branch to establish and implement new sanctions programs, coordinated U.S. sanctions policy with foreign governments, and engaged with private sector stakeholders on a range of U.S. sanctions priorities. Erik’s prior government experience also includes service at the Department of the Treasury’s Office of International Affairs.

Earlier in his career, Erik worked as a project finance attorney and litigator, as a law clerk for the Honorable M. Margaret McKeown of the U.S. Court of Appeals for the Ninth Circuit, and as a research fellow at Stanford University’s Program on Energy & Sustainable Development.

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Photo of Sophie Davis Sophie Davis

Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial

…

Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial sanctions across a range of EU and UK sanctions regimes, assisting corporate clients with complex sanctions issues arising from their continued operations in, or divestments from, Russia, and supporting clients with licensing applications and responding to investigations.

Sophie also assists companies on compliance with anti-bribery and anti-money laundering laws, foreign direct investment requirements, human rights, environmental and sustainability regulatory requirements. Prior to joining Crowell & Moring, Sophie worked in the international trade and regulatory team in another top international law firm, based in London, as well as for a leading New Zealand law firm.

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