LICENSE No. BELARUS-EO14038-2023-1168068-1

Date issued: Feb. 16 2024

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TURBOFAC Commentary (1617 words)

Notes:

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...