On April 19, 2021, the Office of Foreign Assets Control (“OFAC”) issued Belarus General License 2H (“GL 2H”) revoking General License 2G (“GL 2G”), which was due to expire on April 25, 2021. o OFAC Revokes Belarus General License (General License 2G r GL 2G) o BIS Adds Chinese Supercomputing Centers and Companies to Entity List o BIS Issues Interim Final Rule with Corrections/Changes to Military Intelligence End Uses and End Users o FinCEN Seeks Comment on Beneficial Ownership Reporting Requirements The wind down ends at 12:01 a.m. eastern daylight time on June 3, 2021. 2G authorizing U.S. persons to engage in transactions involving nine companies: Belarusian Oil Trade House, Belneftekhim, Belneftekhim USA, Inc., Belshina OAO, Grodno Azot OAO, Grodno Khimvolokno … General License 2H … OFAC Revokes Belarus General License (General License 2G r GL 2G) On April 19, 2021, the Office of Foreign Assets Control (“OFAC”) issued Belarus General License 2H (“GL 2H”) revoking General License 2G (“GL 2G”), which was due to expire on April 25, 2021. On October 22, 2019, the Office of Foreign Assets Control (OFAC) issued General License No. Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. In General License ("GL") No. 2G – General License with Respect to Entities Blocked Pursuant to Executive Order 13405, extending the expiration date of the general license to April 26, 2021. The Classroom will be updated regularly with new content. Thus far, these actions are U.S. only. On 19th April, 2021, it was announced that OFAC is revoking Belarus General License 2G and replacing it with Belarus General License 2H. The Department of the Treasury's Office of Foreign Assets Control (OFAC) is revoking Belarus General License 2G and replacing it with Belarus General License 2H, "Authorizing the Wind Down of Transactions Involving Certain Blocked Entities." On April 19, the Department of Treasury, Office of Foreign Assets Control (“OFAC”) issued Belarus General License 2H (“GL2H”) in advance of the expiration of existing license 2G, which had been set to expire on April 26 at 12:01 a.m. eastern daylight time. OFAC Revokes Belarus General License (General License 2G or GL 2G) Export Control Agencies Coordinated Response Target Russia for Prohibited Chemical Weapon Activities Biden Reverses Trump, Removes Ansarallah (Houthis) Terrorist Designations Belarus General License 2H authorizes a 45-day wind down period for certain transactions involving nine sanctioned Belarusian state-owned … OFAC Revokes Belarus General License (General License 2G or GL 2G). The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is revoking Belarus General License 2G and replacing it with Belarus General License 2H, “Authorizing the Wind Down of Transactions Involving Certain Blocked Entities.”. OFAC extended through June 3, 2021 the authorization of the wind down of transactions involving certain Belarusian entities, otherwise prohibited by the Belarus Sanctions Regulations.. Webinar: US Sanctions Policy – What's happened, and what can we expect from the Biden Administration? Daniel’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. However, on April 19, 2021, rather than extending General License 2G, OFAC revoked General License 2G and issued General License 2H , which prohibits dealings with the above-listed entities, and entities in which they own a 50 percent or greater interest, after a 45-day wind down period that expires on June … Mr. McMillan has extensive experience working with companies in the aerospace and defense industry, as well as companies in the Middle East and other parts of Asia. His practice includes matters that implicate the US International Traffic in Arms Regulations (ITAR), US Export Administration Regulations (EAR), US National Industrial Security Program (NISP), the US Committee on Foreign Investment in the United States (CFIUS), and equivalent non-US laws. View the latest U.S. Trade Actions/Tariffs and Other Countries Retaliatory MeasuresUpdated March 2, 2021, View the latest Section 301 Product ExclusionsUpdated March 8, 2021. Contact On April 19, the Department of Treasury, Office of Foreign Assets Control (“OFAC”) issued Belarus General License 2H (“GL2H”) in advance of … On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (SDNs), and entities in which they own a 50 percent or greater interest. For more than five years, OFAC regularly extended GL 2 G, and earlier versions of it, authorizing U.S. person activity with the following nine sanctioned Belarusian companies: The new GL 2H will end this authorization, allowing only a 45-day wind down period for transactions “ordinarily incident and necessary to the wind down” of transactions involving these nine entities and entities in which they own a 50 percent or greater interest. On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (“SDNs”), and entities in which they own a 50 percent or greater interest. 2G authorizing U.S. persons to engage in transactions involving nine companies: Belarusian Oil … The OFAC website notes the temporary extension of: General License No. There has been media speculation that the E.U. The Office of Foreign Assets Control (“OFAC”) recently tightened sanctions on Belarus by revoking and replacing General License 2G with General License 2H. Mr. McMillan's practice involves compliance counseling; compliance programs; licensing; compliance reviews; internal investigations; voluntary disclosures; administrative enforcement actions; criminal investigations; customs inquiries, audits, detentions, and seizures; and trade-compliance due diligence and post-acquisition integration in mergers and acquisitions. hide. 2H (GL 2H) to authorize a “45-day wind down period” for nine Belarusian entities to enter into certain transactions. and Iran Charged MACON, Ga. – Seven individuals and five corporate entities based in the United States, France, the United Arab Emirates (U.A.E.) General License 2H now requires U.S. persons to wind down transactions involving the following Belarusian Specially Designated Nationals and their subsidiaries by June 3, 2021: Please see our prior blog post on the initial version of the prior general license here. OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to the Belarus Sanctions. The Office of Foreign Assets Control ("OFAC") recently tightened sanctions on Belarus by revoking and replacing General License 2G with General License 2H. On April 19, 2021, the Office of Foreign Assets Control (“OFAC”) issued Belarus General License 2H (“GL 2H”) revoking General License 2G (“GL 2G”), which was due to expire on April 25, 2021. On October 22, 2019, the Office of Foreign Assets Control (OFAC) issued General License No. The Export Controls Classroom is intended to provide insight into the significant challenges and potential compliance risks that export controls pose for global companies. We have negotiated card acceptance and settlement terms with over 600 individual merchants, providing the PPR network with approximately 13,300 fueling sites across the region. Our Trade Law Blog features legal insight and thought-leadership affecting the industries and business reliant and affected by international trade. 2G – General License with Respect to Entities Blocked Pursuant to Executive Order 13405, extending the expiration date of the general license to April 26, 2021. Petrol Plus Region (PPR) network —our primary proprietary fleet card network in Russia, Ukraine, Belarus and Kazakhstan. For more than five years, OFAC regularly extended GL 2 G, and earlier versions of it, authorizing U.S. person activity with the following … He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. In a change from previous versions of General license 2, GL2H is not a normal extension of authorization to conduct business with the list of … Export Control Agencies Coordinated Response Target Russia for Prohibited Chemical Weapon Activities, Biden Reverses Trump, Removes Ansarallah (Houthis) Terrorist Designations, President Biden Imposes Sanctions & Export Controls on Myanmar In Response to Military Coup, OFAC Issues Communist Chinese Military Companies General License 1A and Related Frequently Asked Questions, View the latest U.S. Trade Actions/Tariffs and Other Countries Retaliatory Measures, View the latest Section 301 Product Exclusions, Peter B. Miller, CIPP/G/US, CIPP/E, CIPM, CIPT, Committee on Foreign Investment in the U.S. (CFIUS), Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), Directorate of Defense Trade Controls (DDTC), Executive Order 13873 on Securing the Information and Communications Technology and Services Supply Chain, Executive Order on Hong Kong Normalization, Financial Crimes Enforcement Network (FinCEN), Joint Comprehensive Plan of Action (JCPOA), NY Department of Financial Services (NYDFS), Office of Financial Sanctions Implementation (OFSI), Office of the U.S. Trade Representative (USTR), PATRIOT ACT Section 311 ‘Finding of Primary Money Laundering Concern’, U.K. National Security and Investment Act (NSI), U.S. International Trade Commission (USITC), Proposed Amendments to Trade Act of 2021 to Renew GSP, MTB, and Section 301 Exclusion Process, Chambers and Partners Ranks Crowell & Moring International Trade Attorneys in 2021 Guide, USITC Establishes Pilot Program to Test Interim ALJ Initial Determinations on Key Issues in Sec.
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