June 8, 2016
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) generally prohibits U.S. persons from doing any business with Belarusian parties identified on the Specially Designated Nationals and Blocked Persons (SDN) List, which includes Belneftekhim, the largest exporter of Belarusian products to the United States. On October 29, 2015, however, OFAC published a six-month general license authorizing U.S. persons to engage in transactions with Belneftekhim and certain of its affiliates. On April 28, 2016, OFAC extended the authorization, originally scheduled to expire on April 30th, by issuing another general license scheduled to expire on October 31, 2016.
There are some notable similarities and differences between the original and current general licenses.
Scope of General License Remains Unchanged
Under both general licenses, all property, including interests in property, belonging to the specified entities that were blocked prior to October 30, 2015 remains blocked and may not be dealt in. Additionally, the list of otherwise blocked entities with which U.S. persons are authorized to do business remains the same under the new general license:
Dealings with any other entities blocked pursuant to Executive Order 13405 remain prohibited under the new general license.
Changes in Reporting Requirements
Under the original general license, U.S. persons that engaged in a transaction or series of transactions involving a listed entity and exceeding $10,000 had to file a report with the State Department within 15 days of executing that transaction or series of transactions. Under the current general license, that reporting threshold has been increased to $50,000. In addition, U.S. persons now have 30 days to file the report after executing the transaction(s).
For specific questions regarding the Belarus sanctions or this general license, please contact us.