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Financial Services Law Insights and Observations

OFAC issues Belarus-related General License 2H

Financial Crimes OFAC Department of Treasury Department of State Of Interest to Non-US Persons Belarus Sanctions OFAC Designations

Financial Crimes

On April 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License No. 2H (GL 2H) to authorize a “45-day wind down period” for nine Belarusian entities to enter into certain transactions. GL 2H replaces and supersedes in its entirety General License No. 2G and authorizes all transactions with any entities that are owned by 50 percent or more by the nine named entities. All property and interests in property of these entities, if blocked, remain blocked, and U.S. persons must report authorized transactions or any series of transactions exceeding $50,000 to the U.S. Department of State no later than 30 days after execution. The authorization expires on June 3.

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