Yesterday, the U.S. Office of Foreign Assets Control (OFAC) sanctioned several Belarusian individuals and entities, including the State Security Committee of the Republic of Belarus (the Belarusian KGB), in response to the Lukashenka regime’s escalating violence and repression. (The full list of changes to the Specially Designated Nationals (SDN) and Blocked Persons List is available here).
OFAC also issued Belarus General License 3 (GL 3) to ensure that U.S. persons engaging in legal business activities in Belarus are able to interact with the Belarusian KGB in its administrative capacity. Specifically, GL 3 authorizes U.S. persons to engage in certain activities that are ordinarily incident and necessary to requesting, receiving, utilizing, paying for, or dealing in licenses, permits, certifications, or notifications issued or registered by the Belarusian KGB for the importation, distribution, or use of information technology products in Belarus, provided that any exports of items subject to U.S. export controls are properly licensed and payments of fees to the Belarusian KGB do not exceed 5,000 in any calendar year. GL 3 also authorizes U.S. persons to comply with law enforcement, administrative actions, and investigations involving the Belarusian KGB and with rules and regulations administered by the Belarusian KGB.
Companies that do business in Belarus should carefully review the new additions to the SDN List and ensure that GL 3 covers any required dealings with the Belarusian KGB. GL 3 does not authorize most exports of items to the Belarusian KGB or the transfer of blocked property.