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OFAC General License

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On May 28, 2021, the Biden Administration issued a press release (“Press Release”) confirming the re-imposition of sanctions on certain Belarusian state-owned enterprises (“SOEs”) (presaged by the issuance of wind down Belarus General License 2H on April 19, 2021) and suspending the application of the 2019 US-Belarus Air Services Agreement (“2019 USB Agreement”) in response to the Belarusian government’s apparent forced diversion of a commercial flight to Minsk on May 23. The Press Release also…

On May 18, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 1B, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” (“GL 1B”) in relation to OFAC’s Communist Chinese Military Companies (“CCMCs”) sanctions program as implemented pursuant to Executive Order 13959 (“EO 13959”) and amended by Executive Order 13974. Our blog posts on EO 13959 and OFAC’s prior guidance on the CCMC sanctions program are available here and here. As with the…

On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (“SDNs”), and entities in which they own a 50 percent or greater interest. The revocation of GL 2G effectively strengthens US sanctions against Belarus, and may make it more difficult for US Persons to conduct…

Under the Russian encryption regulations, notification to, or registration with, the Russian Federal Security Service (the “FSB”) is required in order to import and distribute foreign products (hardware and software) with encryption functions or features in the Russian Federation. Although the FSB is a sanctioned party, listed on the Office of Foreign Assets Control (“OFAC”) list of specially designated nationals and blocked persons (the “OFAC SDN List”) pursuant to the Cyber-Related Sanctions Regulations, 31 C.F.R.…