On October 29, 2015, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Belarus-related General License No. 2, authorizing transactions otherwise prohibited by, and involving Belarusian entities blocked pursuant to, Executive Order 13405. The general license is effective only from October 30, 2015 through April 30, 2016, unless extended or revoked.

General License No. 2 applies to all Belarusian entities currently identified as specially designated nationals (“SDNs”) pursuant to Executive Order 13405, and any entities owned, directly or indirectly, 50% or more by one or more of those SDNs, as follows:

1. Belneftekhim

2. Belneftekhim USA, Inc.

3. Lakokraska OAO

4. Polotsk Steklovolokno OAO

5. Belarusian Oil Trade House

6. Belshina OAO

7. Grodno Azot OAO

8. Grodno Khimvolokno OAO

9. Naftan OAO 

All property and interests in property of the entities described above that were blocked prior to October 30, 2015 remain blocked unless authorized by OFAC. General License No. 2 also does not authorize transactions with any other person blocked pursuant to Executive Order 13405 or the Belarus Sanctions Regulations, 31 C.F.R. Part 548, whether directly or indirectly, even if they otherwise involve SDNs covered by General License No. 2.

In addition, General License No. 2 requires that U.S. person engaging in any transaction or series of transactions in excess of $10,000 involving any of the above SDNs file a report with the US State Department’s Office of Eastern European Affairs within 15 days of the transaction’s execution. The reports must include (1) estimated or actual dollar value of the transaction(s), (2) the parties involved, (3) the type and scope of activities conducted, and (4) the dates or duration of the activities.

According to a State Department press briefing, the general license represents a “limited reprieve” from sanctions in response to the Belarusian Government’s release of six political prisoners on August 22, 2015. OFAC may extend General License No. 2 beyond April 30, 2016 or revoke it before that date in response to additional actions by the Belarusian Government. It is not clear or known whether a wind-down or grandfathering period would be included with a revocation. In 2008, OFAC issued a similar general license authorizing transactions with Lakokraska OAO and/or Polotsk Stoklovolokno OAO, in response to the Belarusian Government’s release of political prisoners. OFAC extended that general license five times before revoking it effective February 11, 2011, with a brief wind-down period.


Ms. Kim focuses on outbound trade compliance issues that arise under US economic sanctions, export control laws, investment restrictions, anti-boycott regulations, anti-money laundering laws and the Foreign Corrupt Practices Act. She represents and advises US and non-US companies in criminal and regulatory proceedings, internal investigations, and compliance audits relating to these areas of law. She also advises on the extraterritorial application of these laws in cross-border transactions, including mergers and acquisitions, joint venture arrangements, and other international commercial activities. Her practice includes the development and implementation of workable, risk-based internal compliance programs and procedures for companies in a wide range of industries.


Meg's practice involves assisting multinational companies with export compliance related matters, specifically trade sanctions and export control classifications. Additionally, she assists companies with respect to customs laws, anti-boycott laws and other trade regulation issues in the US and abroad. She also helps obtain authorizations from the US government for activities subject to sanctions regulations and US export control regulations, including the Export Administration Regulations and the International Traffic in Arms Regulations. Meg's practice extends to assistance in internal compliance reviews as well as enforcement actions and disclosures necessitated by US government action.