Belarus General License 5 - Authorizing the Wind Down of Transactions Involving Open Joint Stock Company Belarusian Potash Company or Agrorozkvit LLC (Effective December 02, 2021)

Date issued: Dec. 02 2021

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TURBOFAC Commentary (1474 words)

Notes:

1) Except as discussed below, this is a standard wind-down general license, authorizing the processing of underlying transactions that may not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities.

2) With respect to the scope of the typical "wind-down" GL, consult the relevant portions of Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs.

3) Read in conjunction with FAQ # 939, issued on the same day as this GL. The language in the FAQ concerning "the entry into new purchase contracts [] or the stockpiling of inventory" is identical to the language found in FAQ # 918, which deals with Belarus General License 4, the significance of which is discussed...