On August 9, 2023, marking the three-year anniversary of the fraudulent August 2020 presidential election in Belarus, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new sanctions on eight individuals and five entities, focusing notably on the aviation sector.

Among the designated entities, OFAC has targeted the state-owned flagship carrier of Belarus, Belavia Belarusian Airlines (BELAVIA). Additionally, OFAC has designated Open Joint Stock Company Minsk Civil Aviation Plant 407, a state-owned aircraft component manufacturer. The facility has been highlighted as a key player in Belarusian production to meet Russia’s civil and military aircraft demand. The sanctions also include the designation of Joint Stock Company Byelorussian Steel Works (BSW) and BEL-KAP-STEEL LLC, a joint venture with BSW, which have been pivotal in generating substantial revenue for the Lukashenka regime.

OFAC also issued two Belarus-related General Licenses (GL) to allow for the wind down of activities with certain newly designated entities:

  • General License 8 authorizes all transaction ordinarily incident and necessary to the wind-down of transactions involving Joint Stock Company Byelorussian Steel Works Management Company of Holding Byelorussian Metallurgical Company through 12:01 a.m. EST, October 9, 2023. 
  • General License 9 authorizes all transaction ordinarily incident and necessary to the provision of exports, technology or services to ensure civil aviation safety, and transactions involving the wind-down of any transactions involving BELAVIA, through 12:01 a.m. EST, September 8, 2023.

In addition, sanctions were implemented on members of a Belarusian business and tobacco mogul and close associate of Alyaksandr Lukashenka.  Also, actions were taken against the Department of Financial Investigations of The State Control Committee of the Republic of Belarus and affiliated individuals for their involvement in cracking down on Belarus’s pro-democracy movement and free media.

For additional identifying details on these newly designated individuals and entities, the SDN List is available here.

As a result of these actions, all property and interests in property of the persons placed on OFAC’s SDN List above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50% or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.