May 10, 2021

Over the past several years, OFAC has issued and continually renewed general licenses that authorized certain dealings with the following nine sanctioned Belarusian state-owned entities: Belarusian Oil Trade House, Belneftekhim, Belneftekhim USA, Inc., Belshina OAO, Grodno Azot OAO, Grodno Khimvolokno OAO, Lakokraska OAO, Naftan OAO, and Polotsk Steklovolokno OAO.

The most recent general license, General License 2G, was set to expire on April 26, 2021.  However, on April 19, 2021, rather than extending General License 2G, OFAC revoked General License 2G and issued General License 2H, which prohibits dealings with the above-listed entities, and entities in which they own a 50 percent or greater interest, after a 45-day wind down period that expires on June 3, 2021.  In a press release supporting OFAC’s action, the State Department noted that “[g]iven the sharply deteriorating human rights situation in Belarus, the U.S. Government determined a further extension would be inconsistent with the Belarus Democracy Act and incompatible with American values.”  The previous general licenses had opened up the Belarusian petrochemical industry to U.S. companies by authorizing dealings with Belneftekhim, Naftan, and their numerous subsidiaries.  However, as a result of Belarus’ failure to comply with its obligations under international human rights laws, that door is now closing again.

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