US approves wider sanctions against Belarus targeting governments and key economic sectors | Kelley Drye & Warren LLP

8. Belarus. The PO authorizes the Office of Foreign Assets Control (OFAC) to impose sanctions on parties that are part of the “Government of Belarus”, all units owned or controlled by the government and units involved in security , Energy, potassium chloride (potash), tobacco, construction or transport sector of the Belarusian economy.

According to the new EO and existing authorities, OFAC yesterday added 23 natural persons and 21 legal entities to its Specially Designated Nationals (SDN list), which by and large prohibits US persons from doing business with the newly sanctioned parties and freeze any property of the sanctioned parties that is under US jurisdiction. OFAC targeted the Belarusian oligarchs Mikalai Varabei and Aliaksey Aleksin as well as the Serbian Karic family and their holdings in Belarus. Companies associated with these parties include major players in the Belarusian energy, freight and tobacco industries. OFAC also referred to Belaruskali OAO, a large potash producer, Grodno Tobacco Factory Neman, and several directors of other previously sanctioned state-owned companies. Limited transactions required to process existing business with Belaruskali OAO are authorized until December 8, 2021 under a general license issued by OFAC. Actions yesterday also include sanctions against individuals and organizations involved in human rights abuses, the repression of peaceful protesters and the diversion of Ryanair flight 4978.

Companies doing business in Belarus should carefully examine these developments and any business dealings with the newly sanctioned parties or other companies majority-owned by the new SDNs that may now be banned. Further sanctions against state-owned companies, the Belarusian government and the other sectors mentioned in yesterday’s PO are possible.

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