December 7, 2023

OFAC imposes Belarus-related sanctions upon financial supporters of the Lukashenka regime and Russia’s war against Ukraine

On December 5, 2023,  the US Department of the Treasury’s Office of Foreign Assets Control sanctioned a number of individuals and entities in Belarus to increase pressure on the Lukashenka regime for its support of Russia’s war against Ukraine and the regime’s suppression of Belarus’s democratic civil society and corrupt enrichment of the Lukashenka family.  To this end, OFAC designated Dzmitry Shautsou, the Secretary General for the Belarus Red Cross, pursuant to Executive Order 14024 for his alleged support of Maria Lvova-Belova, Russia’s Commissioner for Children and her unlawful practice of deporting and transferring children from Russian-occupied areas of Ukraine to Belarus.  OFAC also designated 11 entities and 7 individuals in Belarus under EO 14038 for their alleged role in supporting Russia’s illegal war against Ukraine, generating funds for the Lukashenka regime or acting as Lukashenka’s so-called personal “wallets.”  These individuals and entities were designated for being owned or controlled by the Government of Belarus (“GoB”), acting on behalf of the GoB, or for operating in a significant sector of the Belarus economy, including its defense sector.

Among the newly designated Belarusian revenue generators are Pavel Georgievich Topuzidis and Viktor Evgenievich Petrovich, two Belarusian oligarchs who control 30 percent of Belarus’s tobacco production and allegedly serve as important “wallets” for Lukashenka and his regime.  OFAC also designated their business Tabak Invest LLC, which was the only private tobacco producer in Belarus until 2017.  According to investigative journalists in Belarus, Tabak Invest has generated millions of dollars in revenue for the company by engaging in a scheme to smuggle cigarettes into Russia.

Three state-owned enterprises were also designated for operating in Belarus’s defense sector, including the JSC Minsk Mechanical Plant Named After SI Vavilov Management Company of BelOMO Holding (“BelOMO”) that manages several other defense-sector entities in Belarus, two of which are newly designated along with their director generals.  Alexander Ivanovich Moroz, the Director General of BelOMO, is among the new OFAC designees.  Three additional Belarusian companies were designated for supporting Russia’s war against Ukraine, including the Open Joint Stock Company Alevkurp, a state-owned military manufacturer of radar systems that received an award from the Russian government for developing export-oriented military products.

As a result of these designations, all property and interests in property of these designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving designated persons.  In addition, entities owned 50 percent or more by one or more blocked persons are blocked.

OFAC concurrently issued General License 10 pursuant to Belarus Sanctions Regulations (“BSR”), 31 CFR part 548, in order to authorize wind down transactions involving Tabak Invest or any entity in which the company owns a 50 percent or greater interest.  GL 10 authorizes wind down transactions until February 2, 2023, provided that payments made to blocked persons are make into a blocked account at a US financial institution in accordance with the BSR.

Department of Treasury Press Release | General License 10