On June 21, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Belarus General License 3 (“GL 3”) authorizing certain transactions with the newly designated State Security Committee of the Republic of Belarus (“Belarusian KGB”) along with related FAQs (FAQ 912 and FAQ 913).  In addition to the Belarusian KGB, OFAC designated 16 new parties to the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to Executive Order 13405, including state-owned security entities and associates of Belarusian President Alexander Lukashenko for having found to be involved in the suppression of peaceful protests following the 2020 Belarusian Presidential election.  For additional details on the Biden Administration’s sanctions on Belarus and the suspension of the 2019 US-Belarus Air Services Agreement, please see our prior blog post here.

Issuance of GL 3 and Related FAQs

GL 3 generally authorizes transactions with the Belarusian KGB, provided that such transactions and activities are necessary and ordinarily incident to:

  1. 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 such transactions are licensed or authorized by the US Department of Commerce where required and any fee payments to the Belarusian KGB for such licenses, permits, certifications, or notifications do not exceed $5,000 in any calendar year;
  2. complying with law enforcement or administrative actions or investigations involving the Belarusian KGB; and
  3. complying with rules and regulations administered by the Belarusian KGB.

The newly issued FAQs clarify that GL 3 does not authorize the exportation, reexportation, or provision of any goods, technology, or services except for the purpose of complying with rules and regulations administered by the Belarusian KGB.

SDN Designations of Parties Involved in Human Rights Abuses and Associates of President Lukashenko

Notable SDN List additions include President Lukashenko’s press secretary, Natallia Mikalaeuna Eismant, and the Chairperson of the Belarusian Parliament’s upper house, Natallia Ivanauna Kachanava.  OFAC also designed state security entities, such as the Belarusian KGB and the Ministry of Internal Affairs’ Internal Troops. As a result of designations under Executive Order 13405, “US Persons” (i.e., (i) US citizens and permanent resident aliens / Green Card holders, wherever located or employed; (ii) entities organized under the laws of the United States, their non-US branches, and employees of the foregoing; and (iii) any individual or entity physically located in the United States, even temporality) are prohibited from directly or indirectly dealing with or facilitating virtually any transactions with such designated parties as well as any entities 50% or more owned by them.  Any property and interests in property of such parties must also be blocked if they come within the United States or the possession or control of a US Person, including but not limited to a US financial institution clearing or otherwise handling US dollar transactions that involve these SDNs.


Paul Amberg is a partner in Baker McKenzie’s Amsterdam office, where he handles international trade and compliance issues. He advises multinational companies on export controls, trade sanctions, antiboycott rules, customs laws, anticorruption laws, and commercial law matters. Paul helps clients assess and address compliance risks presented by export controls, trade sanctions, antiboycott rules, customs laws, and anticorruption laws. His practice especially focuses on internal reviews, voluntary disclosure filings, and enforcement actions brought by, the US Government in relation to the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), trade and economic sanctions programs, and US customs laws.


Eunkyung advices clients on various regulatory compliance and trade issues, concentrating on the US export controls such as the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR), economic and trade sanctions, US customs and import laws, the US Foreign Corrupt Practices Act (FCPA), and foreign anti-bribery laws.


Andrea practices international commercial law with a focus on cross-border transactions including post-acquisition integration IP migrations and technology licensing. She also advises companies on export controls, sanctions, customs and international corporate compliance. Andrea also has an active pro bono practice, including helping organizations with international constitutional matters and victims of domestic abuse.