Case No. BEL-2014-313440-1

Date issued: Apr. 18 2016

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TURBOFAC Commentary (550 words)

Notes:

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). ...