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LICENSE No. BELARUS-EO14038-2023-1168068-1
BELARUS SANCTIONS REGULATIONS
LICENSE
(Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, Executive Orders 13405 and 14038, and 31 C.F.R. Parts 501 and 548.)
To: Crossover, Inc.
c/o Derbes Law Firm LLC
3027 Ridgelake Drive
Metairie, Louisiana 70002
Attn: Albert J. Derbes, IV
1. Based upon the request dated November 22, 2023, on behalf of Crossover, Inc., and information otherwise available to the Office of Foreign Assets Control (the "Application"), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and instructions issued under any of the authorities cited above.
3. This License expires on...
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1) ESSENTIAL BACKGROUND
The background of this case is as follows: on October 21, 2022, a U.S. person purchaser ordered steel from a Belarusian entity (BSW) through its U.S. distributor (Distributor) (see p. 5, PDF). On April 10, 2023, Distributor sent an invoice to U.S. person purchaser “in connection with money owing for the purchase order” (id). This appears to be the same date on which the steel was actually delivered to the U.S. person (see p. 30, PDF). On August 2, 2023, U.S. person purchaser “received notice from [U.S. person distributor] to pay the invoice” (p. 5, PDF). On August 9 2023, OFAC blocked BSW, and concurrently issued Belarus GL 8, authorizing “ordinarily incident and necessary to the wind down of any transaction involving [BSW]…through… October 9, 2023, provided that any payment to a BSW Entity must...