On March 26, 2026, the U.S. Department of the Treasury (Treasury), Office of Foreign Assets Control (OFAC) rescinded Directive 1 under Executive Order (E.O.) 14038, which had prohibited transactions in Belarusian sovereign debt with maturity of longer than 90 days issued since December 2, 2021. In parallel with the rescission of Directive 1, OFAC issued General License (GL) 14, authorizing transactions involving the Belarussian Bank of Development and Reconstruction Belinvestbank Joint Stock Company (Belinvestbank), among other entities. OFAC also removed several significant Belarusian potash sector entities from the Specially Designated Nationals and Blocked Persons List (SDN List).
The rescission of Directive 1, issuance of GL 14, and removal of entities from the SDN List together remove restrictions on certain key elements of the Belarusian economy, namely its financial infrastructure and the export-oriented fertilizer sector. These actions follow joint talks between the United States and Belarus held in March and President Lukashenko’s subsequent release of 250 prisoners, amid broader efforts to normalize bilateral ties.[1] The easing of these restrictions also comes amid the ongoing conflict in Iran and the Middle East, which is reported to have disrupted fertilizer exports, including potash, from the Persian Gulf region, contributing to rising global fertilizer prices and increased input costs for U.S. agricultural producers.[2]
Rescission of Directive 1 and Sovereign Debt Prohibitions
Directive 1, issued in December 2021 under E.O. 14038, prohibited U.S. persons from transacting or participating in the primary and secondary markets of new Belarusian sovereign debt, in any denomination, with a maturity of greater than 90 days issued by the Ministry of Finance or the Development Bank of the Republic of Belarus (DBRB).[3] Directive 1 was originally issued as part of a coordinated effort with the European Union, the United Kingdom, and Canada in response to alleged human rights abuses and the erosion of democratic norms in Belarus.
Following the rescission of Directive 1,U.S. persons are no longer prohibited from transacting in or providing financing for Belarusian sovereign debt instruments issued by the Ministry of Finance or the DBRB. However, other restrictions under the Belarus Sanctions Regulations (BSR), 31 C.F.R. Part 548, as well as prohibitions relating to SDNs more generally, continue to apply.
Issuance of GL 14 and Delisting of Potash Sector Entities
GL 14 authorizes all transactions otherwise prohibited by the BSR involving Belinvestbank, Limited Liability Company Belinvest-Engineering (Belinvest-Engineering), CJSC Belbizneslizing (Belbizneslizing), or any entity in which one or more of those entities own a 50 percent or greater interest. GL 14 does not authorize the unblocking of blocked property or any transactions otherwise prohibited by the BSR, including transactions involving the property or interests in property of any person blocked pursuant to the BSR other than the blocked persons identified in GL 14, unless separately authorized by OFAC.
Concurrently with the issuance of GL 14, OFAC also removed from the SDN List a number of entities in the Belarusian potash sector that were designated around the time Directive 1 was issued. OFAC had previously incrementally eased sanctions targeting the potash sector in December 2025 through GL 13, which authorized certain transactions involving state-owned Belaruskali OAO (Belaruskali) and its subsidiaries, collectively one of the world’s largest producers of potash, OJSC Belarusian Potash Company (BPC), the primary exporter of Belarusian potash, and Agrorozkvit LLC (Agrorozkvit), BPC’s Ukrainian subsidiary. With this latest action, OFAC formally removed Belaruskali, BPC, and Agrorozkvit from the SDN List.
EU and UK Sanctions
Following the latest actions by OFAC, the EU and UK sanctions regimes relating to Belarus remain significantly stricter than those of the United States. Belaruskali and BPC, as well as certain Belarusian banks and financial institutions, remain individually listed on EU and UK sanctions lists, and entities owned or controlled by those sanctioned entities may also fall within the scope of EU and UK asset-freeze sanctions. EU sectoral sanctions — which prohibit dealing in the sovereign debt of Belarus and certain financial institutions, where that debt has a maturity exceeding 90 days and was issued after June 29, 2021 — also remain in place. As a result, any transaction involving such debt through financial service providers such as Euroclear or Clearstream continues to be prohibited, notwithstanding OFAC’s rescission of Directive 1. The position under the UK regime is similar: a number of Belarusian potash and financial entities remain individually listed, and restrictions on dealing in sovereign debt likewise remain in force.
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Cleary Gottlieb’s international trade team continues to monitor developments regarding sanctions and trade developments with respect to the ongoing conflict in the Middle East, and is available to offer guidance on managing the changing regulatory landscape.
[1] See Andrius Sytas and Mark Trevelyan, Lukashenko Frees 250 Belarusian Prisoners as U.S. Removes More Sanctions, Reuters, March 19, 2026, available here.
[2] See Fatima Hussein, U.S. Eases Belarus Sanctions as Trump Says He’ll Help U.S. Farmers Impacted by Iran War, AP News, March 26, 2026, available here.