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Case No. BEL-2014-313440-1
[ ], Esq.
[ ]
3050 K Street, NW
Suite 400
Washington, D.C. 20007-5108
Dear [ ]
This responds to your request dated October 22, 2014 (the Application), on behalf of Flowserve Netherlands B.V., a wholly owned subsidiary of Flowserve Corporation, a U.S. entity, (collectively, Flowserve), to the Office of Foreign Assets Control (OFAC), requesting guidance as to whether Mozyr Oil Refinery JSC (Mozyr Oil) is a blocked entity pursuant to the Belarus Sanctions Regulations, 31 C.F.R. Part 548. According to the Application, the State Property Committee of the Republic of Belarus owns 42.76 percent of Mozyr Oil. You further state that it appears that Belneftekhim “may manage” 55.01 percent of the state-owned shares of Mozyr Oil.
On June 16, 2006, President Bush issued Executive Order (E.O.) 13405 in...
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1) Background
Belarusian State Concern for Oil and Chemistry (“Belneftekhim”) is “is an association of petrochemical companies in Belarus, subordinated to the Council of Ministers. It manages these companies and regulates several aspects of the petrochemical sector, including setting retail prices for gasoline.” (https://en.wikipedia.org/wiki/Belneftekhim 9-2-24). OFAC designated Belneftekhim in 2007, characterizing it as a “petrochemical conglomerate” (https://home.treasury.gov/news/press-releases/hp676). Belneftekhim appears to operate such that it does not own significant companies outright in the traditional sense; instead, the government owns the companies and Belneftekhim controls them by acting as a regulatory body, providing guidance, policy direction, and strategic planning. According to the Belneftekhim website, Belneftekhim “carries out, in accordance with the established procedure, control over the financial and economic activities of the [Belneftekhim] enterprises that are [owned by the Government]” (see https://www.belneftekhim.by/ru/tasks-ru/; machine translated). ...