BEL-145-1
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450 Taraval Sheet, #147
San Francisco, CA 94116
Dear Mr.[ ]:
This in response to your letter dated February 28, 2011, in which you seek additional information related to the Office of Foreign Assets Control's (OFAC) licensing determinations for Case Nos. BEL-25, BEL-58, and BEL-64. We understand from your request that you would like information regarding the regulations under which these determinations were issued.
As noted in OFAC's responses to the above referenced cases, the blocked funds transfer in question involves an entity designated pursuant to Executive Order (E.O.) 13405, "Blocking Property of Certain Persons Undermining Democratic Processes or Institutions in Belarus," specifically the UE Belarusian Oil Trade House (BOTH), designated on May 15, 2008. OFAC previously noted that, prior to the designation of BOTH, the Belarusian State Concern...
1) On 02/14/2008, OFAC published (on the web) the first version of its “ Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked,” (i.e. the 50 Percent Rule), and on 3/6/2008, OFAC issued its Guidance on the Blocking of Property of Certain Persons Undermining the Democratic Processes or Institutions in Belarus by Executive Order 13405, specifically referencing the 50 Percent Rule guidance, and noting that “U.S. persons who have or who are contemplating business relationships with entities in which Belfneftekhim owns, directly or indirectly, a 50% or greater interest should be aware that the property and interests in property of such entities are blocked pursuant to E.O. 13405, regardless of whether the entities themselves are listed in the annex of E.O. 13405 or otherwise placed on OFAC's list of Specially Designated Nationals.” On Feb. 3,...