Treasury Authorizes Transactions With Belarusian Potash Companies

On December 15, 2025, the Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued Belarus General License 13, "Authorizing Transactions Involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, and Belaruskali OAO." The general license authorizes all transactions prohibited by the Belarus Sanctions Regulations, 31 CFR part 548 ("BSR"), involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, Belaruskali OAO, and any entity in which one or more of these entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. However, the general license does not authorize the unblocking of any blocked property, nor does it permit transactions involving any other blocked persons under the BSR beyond the three specifically named entities and their majority-owned subsidiaries.

This development brings Belarus closer to Russia in terms of U.S. sanctions relief for exports of potash, a key input in fertilizers essential for global food production and crop yields. The significance of this action is amplified by the fact that Belaruskali is one of the largest state-owned companies in Belarus, making potash exports a meaningful source of revenue for the Belarusian regime.

This notable shift in U.S. sanctions policy toward Belarus contrasts sharply with the European Union ("EU")'s approach to Belarusian potash and broader sanctions policy. The EU maintains comprehensive restrictions on imports of potash from Belarus under its sanctions framework targeting the Lukashenko regime, which were implemented following the 2020 presidential election and subsequent crackdown on political opposition. JSC Belarusian Potash Company and Belaruskali OAO (along with any entities they own or control) also remain sanctioned by the EU. While the EU has carved out certain humanitarian and agricultural exemptions in its Belarus sanctions program, potash imports remain generally restricted, creating a divergence between U.S. and EU sanctions policies on this commodity.

More recently, the EU broadened its Belarus sanctions regime this week by adding a new asset freezing designation criterion for individuals/entities who (i) plan, direct, engage in support or facilitate foreign information manipulation and interference; (ii) target the functioning of democratic institutions; (iii) enter an EU member state without authorisation; or (iv) interfere with, damage or destroy critical infrastructure. The EU has stated that this new criterion was linked to recent meteorological balloon incursions into Lithuania's airspace, demonstrating a continued commitment from the EU to maintaining pressure on the Minsk regime.

It is also worth noting that potash was subject to the initial Trump tariffs earlier this year, specifically impacting Canadian and Mexican imports. According to U.S. Customs and Border Protection, these tariffs affected potash imports from North America, adding another layer of trade policy complexity to this critical agricultural input.

Crowell & Moring will continue to monitor developments related to Belarus sanctions and their potential impact to industry.

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