On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (SDNs), and entities in which they own a 50 percent or greater interest. The revocation of GL 2G effectively strengthens US sanctions against Belarus, and may make it more difficult for US Persons to conduct business in that country.

OFAC concurrently issued Belarus General License 2H, “Authorizing the Wind Down of Transactions Involving Certain Blocked Entities” (“GL 2H”), which authorizes certain wind down transactions with the nine sanctioned entities through 12:01 AM EDT on June 3, 2021. GL 2H requires that all US Person participation in wind down transactions in excess of $50,000 be reported to the US Department of State within 30 days of their execution.

Please see our prior blog post on the initial version of the prior general license here.