On Tuesday, October 24, 2017, OFAC issued General License No. 2D with respect to the Belarus Sanctions Regulations, replacing General License No. 2C. The terms of General License No. 2D remain identical to those of 2C, but 2D’s authorization now extends through April 30, 2018.
Specifically, General License No. 2D authorizes (with stated exceptions and terms described below) all transactions otherwise prohibited by E.O. 13405 involving the following entities:
• Belarusian Oil Trade House
• Belneftekhim USA, Inc.
• Belshina OAO
• Grodno Azot OAO
• Grodno Khimvolokno OAO
• Lakokraska OAO
• Naftan OAO
• Polotsk Steklovolokno OAO
General License 2D also authorizes transactions that are owned 50% or more by any of the above entities, individually or in the aggregate, directly or indirectly. U.S. persons must report their transactions over $50,000, directly or indirectly involving any of these nine entities (or those entities owned 50% or more by them), within 30 days to the Office of Eastern European Affairs within the U.S. Department of State. The $50,000 threshold is also triggered by any series of transactions exceeding $50,000. Reports must include: 1) estimated/actual dollar value of the transaction(s) (in terms of value of goods, services, or contract); 2) parties involved; 3) type and scope of activities conducted; and 4) dates/duration of activities.
Still prohibited are transactions with persons whose property and interests in property are blocked pursuant to 31 C.F.R. § 548.201(a) or E.O. 13405, even if those transactions occur through any of the nine entities listed above (or those entities owned 50% or more by them).
More information can be found on OFAC’s website at https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20171024.aspx.
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