Belarus General License 3 - Authorizing Certain Transactions with the State Security Committee of the Republic of Belarus (Effective June 21, 2021)

Date issued: Jun. 21 2021

TURBOFAC Commentary (135 words)


1) Compare Cyber General License (No. 1B), a substantively identical GL applicable to the Russian Federal Security Service (FSB).

2) By its terms, the GL is not limited to activities in which a U.S. person is a party to an underlying transaction. This means that U.S. persons may engage in ancillary transactions that would be subject to the otherwise-applicable prohibitions, even if such activities pertain to a transaction involving no U.S. person. For example, the U.S. person “facilitation” of transactions between non-U.S. person subsidiaries and the Belarusian KGB is authorized, provided that they otherwise fall within the scope of the GL. Compare e.g. FAQ # 661, comments thereto. See also FR Notice Explaining OFAC's Implementation of Sec. 218 of the TRA (77 FR 75849, Dec. 26, 2012).