2C or not 2C – that is OFAC’s question

Yes, Mr. Watchlist is enjoying the puns…

On Friday, OFAC replaced Belarus General License 2B with 2C, which authorizes transactions with the following entities: 


  • Belarusian Oil Trade House

  • Belneftekhim

  • Belneftekhim USA, Inc.

  • Belshina OAO

  • Grodno Azot OAO

  • Grodno Khimvolokno OAO

  • Lakokraska OAO

  • Naftan OAO

  • Polotsk Steklovolokno OAO 

and any 50% Rule entities associated with them.

If you do more than $50,000 in transactions, you have to report this to the State Department either by snail mail or email (BelarusGL@state.gov). 

Also, as is kind of standard, any blocked property remains blocked.

This General License, like the ones issued under the Kingpin counter-narcotics trafficking sanctions, basically just extends the expiration date of the authorization – this one till October 30th of this year.


OFAC Notice

Belarus General License 2C

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