On August 9, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 19 individuals and 14 entities for their continued support of “Russia’s war in Ukraine through military resource production and transshipment of goods to Russia, sanctions evasion on behalf of Belarusian defense entities, and revenue generation for Belarusian oligarchs in Alyaksandr Lukashenka’s inner circle.” These sanctions and designations by OFAC follow similar restrictive measures implemented by Canada, the European Union,  and the United Kingdom

The entities and individuals designated by OFAC and placed on the Specially Designated Nationals (SDN) List are engaged in various Belarusian economic sectors, including: (i) technology and defense-industrial industries, (ii) cargo airline companies, (iii) logistics and transportation services, and (iv) several defense manufacturing plants.  OFAC has also designated an aircraft owned by the Government of Belarus that is used as part of Lukashenka’s fleet of presidential aircraft.  For additional identifying details on these individuals, entities and the aircraft see here.

For the involved airline companies, OFAC has issued Belarus General License No. 101 authorizing all transactions that are ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation involving these designated entities.  Certain transactions with these entities remain unauthorized under this general license and therefore requires close analysis.

As a result, all property and interests in property of the designated persons 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, individually or in the aggregate, 50% or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. 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.