April 19, 2021

OFAC replaces broad authorization for transactions with sanctioned entities in Belarus with more limited wind-down authorization in general license 2H

On April 19, 2021, the Department of the Treasury’s Office of Foreign Assets Control replaced Belarus General License 2G with Belarus General License 2H, “Authorizing the Wind Down of Transactions Involving Certain Blocked Entities.”  General license 2H authorizes wind down transactions with nine listed entities until June 3, 2021, including wind down transactions with any entity that is directly or indirectly owned 50 percent or more by one of the listed entities. It is important to note that General license 2G, which is now revoked, and its predecessors provided a broader authorization to allow U.S. persons to generally engage in transactions with the sanctioned entities without winding down those activities.

Under general license 2H, US persons that engage in transactions in excess of $50,000 are required to report the transaction to the US State Department no later than 30 days after the its execution, with certain exceptions. General license 2H is effective immediately and replaces and supersedes general license 2G dated October 22, 2019 in its entirely.

Department of Treasury Recent Action | General License 2H