OFAC Gives Belarus Airline Wings

(OFAC) has issued General License No. 11, authorizing certain transactions involving Open Joint Stock Company Belavia Belarusian Airlines, the state-owned flag carrier of Belarus. In a related action, BIS issued a letter authorizing, among other activities, flights of certain Belavia aircraft between Belarus and most other destinations.

Belavia, wholly owned and controlled by the Government of Belarus, was designated by OFAC in August 2023 under Executive Order 14038 for acting on behalf of the Belarusian state. The designation placed the airline and any majority-owned subsidiaries on the Specially Designated Nationals (SDN) list, effectively cutting off access to Western financial systems and prohibiting most business dealings.

Since May 2021, the airline has been banned from the EU, the UK, Switzerland and Ukraine for its role in the diversion and forced grounding of Ryanair Flight 4978 to arrest opposition activist and journalist Roman Protasevich.

In April 2022 the US Department of Commerce restricted flights on Belarusian owned or operated aircraft manufactured in the US.  This Temporary Denial Order lapsed in December 2024.

Under the new license, OFAC will allow all transactions otherwise prohibited by the Belarus Sanctions Regulations (31 CFR Part 548) that involve Belavia or entities it owns 50 percent or more of.  The move provides limited relief for commercial operations that had been barred, including dealings with international service providers.

Belavia's fleet as of September 2025 includes Airbus A330-200s, Boeing 737-300s, Boeing 737-800s, Boeing 737 MAX 8, Embraer 175s, and Embraer 195s. The fleet also includes a Canadair Regional Jet (CRJ200) and several government-owned aircraft such as a Boeing 767-300. Recent additions include the Airbus A330-200 in June 2025 and a Boeing 737 MAX 8.

The license does not authorize the unblocking of any property already frozen, nor does it extend to transactions involving other Belarusian persons or entities sanctioned under the same program.

Treasury emphasized that the action does not override other U.S. controls, including the Export Administration Regulations administered by the Commerce Department or the International Traffic in Arms Regulations overseen by the State Department.

While General License No. 11 offers a narrow pathway for legal engagement with Belavia, the airline remains subject to sanctions as a state-owned enterprise of Belarus.

BIS Issues Statement of Licensing Policy authorizing Blavia Transactions: 

On September 12, 2025, BIS issued a letter authorizing, among other activities, flights of certain Belavia aircraft between Belarus and most other destinations. This letter also authorizes the service, maintenance, repair, overhaul, or refurbishing of such aircraft. See Letter Authorization.

Consistent with this letter, BIS has removed eight Belavia aircraft from its General Prohibition 10 (GP10) list, whose continued listing would otherwise prevent the maintenance, repair, overhaul, or refurbishing of such aircraft. See Updated GP10 List.

For exports, reexports, or transfers (in-country) of equipment, supplies, and materials that remain subject to an export license to or for use in connection with Belavia aircraft, license applications now will generally be reviewed on a case-by-case basis to determine whether the items are for the maintenance and use of Belavia’s commercial passenger fleet, and to guard against the risk of diversion to other unsupported end-uses or end-users.

Russian Carriers Still Subject to TDOs.

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