Beginning in 2004, in the run-up to the country’s 2006 Presidential election, the EU and the US have imposed increasingly stringent sanctions against Belarus, seeking to counter an increase in political repression. Most of these measures were discontinued in 2016, reflecting the view that the conduct of the Belarus government had improved. In September and October 2020 new sanctions were placed on senior members of the Administration for alleged ballot fraud in the country’s Presidential Election. Sanctions pressure steadily increased on Belarus throughout 2021, including the increased targeting of state-owned companies and government officials. In 2022 Belarus faced further sanctions linked to its role in the Russian-led invasion of Ukraine.
On 26th February 2024 the EU renewed its sanctions programme on Belarus until 28th February 2025.
Sanction Name
Restrictive Measures In Respect Of Belarus
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban:
• Individuals suspected to be involved in the unresolved disappearances of four Belarusian citizens between 1999 and 2000.
• Senior personnel of the Belarussian administration, those considered to be close to President Lukashenko, including the President himself, as well as senior military figures for the their role in Russia’s invasion of Ukraine.
Trade Restriction:
• Exportation of equipment or the provision of technical or financial assistance which may be used for internal repression. This includes a ban on the trading of equipment, technology or software intended primarily for use in the monitoring or interception of the internet and of telephone communications and dual-use goods and technologies for military use and to specified persons, entities or bodies in Belarus.
• On 3rd March 2022 the EU prohibited the sale, supply, and export of any military technology to Belarus via export controls. On 10th March 2022 prohibited the provision of SWIFT services to Belagroprombank, Bank Dabraabbyt and the Development Bank of the Republic of Belarus and their subsidiaries, as well any euro denominated transactions with any person or entity in Belarus or for use in Belarus.
Exemptions
1. Exemptions to travel bans can be granted on a case-by-case basis for humanitarian grounds or for attending inter-governmental meetings.
2. Certain types of small-calibre sporting rifles, pistols and ammunition.
Sanction Name
Regulation on measures against Belarus
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban:
• Individuals suspected to be involved in the unresolved disappearances of four Belarusians between 1999 and 2000
• Senior personnel of the Belarussian administration and those considered to be close to President Lukashenko; Lukashenko himself is not subject to sanctions.
Exemptions
1. Travel ban exemptions may be granted on a case-by-case basis on humanitarian grounds or in relation to the attendance of meetings of international organisations concerning politics in Belarus, or for the protection of Swiss interests.
2. Asset freeze exemptions may be granted to protect Swiss interests or to prevent cases of rigor.
On 9th August 2024, OFAC took action against 19 individuals, 14 entities, and one aircraft pursuant to Belarus-related Executive Order 14038. This action targets persons involved in supporting Russia’s war in Ukraine through military resource production and transshipment of goods to Russia, sanctions evasion on behalf of Belarusian defense entities, and revenue generation for Belarusian oligarchs in Alyaksandr Lukashenka’s inner circle. The Department of State also took steps to impose visa restrictions on 19 regime officials and their affiliates for their involvement in undermining democracy in Belarus, pursuant to Presidential Proclamation 8015.
Sanction Name
Specially Designated Nationals For Certain Persons Undermining Democratic Processes or Institutions in Belarus
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National:
• Individuals involved in human rights abuses, political repression, ballot fraud and public corruption.
• Individuals and entities operating in the defence, security, energy, potash, tobacco, construction and tobacco sectors which have engaged in actions threatening the peace, security or territorial integrity of Belarus.
• On 9th August 2021 President Biden signed Executive Order 14038, Blocking Property of Additional Persons Contributing to the Situation in Belarus, expanding the scope of the previous Executive Order to include individuals and entities operating in a range of sectors including defence, security, energy, potash, tobacco, construction and transportation.
Exemptions
1. OFAC has authorised transactions with nine entities that would otherwise have been prohibited. US persons engaging in transactions exceeding $50,000 with these entities are required to file a report with the US Department of State, Office of Eastern European Affairs within 30 days of the transaction.
2. On 24th February 2022 OFAC released two General Licenses (6 & 7), the first of which authorised all transactions relating to official US government business. General License 7 permitted all transactions related to the UN and its related organisations, the International Centre for Settlement of Investment Disputes (“ICSID”) and the Multilateral Investment Guarantee Agency (“MIGA”), a number of continental development banks such as the EBRD and the business of the Red Cross.
3. On 9th August 2023 OFAC issued Belarus General License 8, authorising the wind down of transactions involving Byelorussian Steel Works Management Company, and Belarus General License 9, authorising transactions related to civil aviation safety or the winding down of dealings with Belavia Belarusian Airlines.
4. On 5th December 2023 OFAC issued general License 10, authorising certain transactions involving Tabak Invest LLC.
Links 1
Sanction Name
Republic of Belarus (Sanctions)(EU Exit) Regulations 2019
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban:
• Individuals suspected to be involved in the unresolved disappearances of four Belarusian citizens between 1999 and 2000.
• Senior personnel of the Belarussian administration, including President Lukashenko himself, as well as those deemed to have facilitated Russia’s invasion of Ukraine via supplying to the country’s military.
• Individuals and entities which:
i) Hold the right to nominate a director or trustee of a government-affiliated entity or who work for the government of Belarus
ii)Obtain a financial benefit from, and immediate family members of, individuals involved in the disappearances of opposition figures Yury Zakharanka, Viktar Hanchar, Anatol Krasouski or Dmitry Zavadski in 1999 and 2000.
Trade Restriction:
•Export of equipment or the provision of technical or financial assistance which may be used for internal repression or in support of Russia’s invasion of Ukraine, as well as a number of strategic sectors including diamonds and rubber.
•Export of banknotes, chemical and biological weapons-related goods and machinery-related goods, as well as the importation from Belarus of gold, gold jewellery, cement, rubber, wood, and aluminium.
Other
•An obligation for social media services and internet service providers to ensure that they take a reasonable steps to prevent users from accessing online content generated by designated persons.
Exemptions
1. Exemptions to travel bans can be granted on a case-by-case basis on humanitarian grounds or to enable the attendance of inter-governmental meetings.
2. Certain types of small-calibre sporting rifles, pistols and ammunition are exempted from the arms embargo.
3. On 12th July 2022 OFSI extended its Belarus sanctions program, expanding the criteria for designation to those providing logistical support to the Russian army, spreading disinformation, or acting in sectors deemed to be of economic or strategic significance to the government’s support for the invasion of Ukraine. Transport-related amendments have prohibited Belarussian ships from entering UK ports and conferred powers on the Secretary of State to detain Belarusian ships at UK ports or anchorages.
4. On 17th October 2022 OFSI indefinitely authorised designated people or entities under its Belarus sanctions program to pay funds to the London Court of International Arbitration to cover arbitration costs, and the LCIA to direct and receive any such funds to pay for arbitration costs.
5. On 29th April 2024 OFSI published a general license amending the fee caps for law firms receiving payments from designated persons to whom they had prior obligations.
