Restrictive measures against Belarus
29 June 2024
Further restrictive measures against Belarus were adopted by Regulation 2024/1865 amending Regulation 765/2006:
The provision of certain services to the Republic of Belarus, its Government, its public bodies, corporations or agencies, or any natural or legal person, entity or body acting on their behalf or at their direction, namely accounting services, auditing services, including statutory audits, bookkeeping services, tax consultancy, business and corporate consultancy and public relations services, shall be prohibited.
The provision of architectural, engineering, IT and legal consultancy services to Belarus shall be prohibited.
Additional restrictions related to export/import/transport of goods (dual-use goods, diamonds, luxury goods, etc.).
The non-circumvention provision is amended to clarify that the elements of knowledge and intent are met not only where a person intentionally seeks to achieve the object or effect of circumventing restrictive measures, but also where a person who engages in an activity the object or effect of which is to circumvent restrictive measures is aware that such engagement may have such object or effect and consents to that possibility.
3 August 2023
Further restrictive measures against Belarus were adopted by Regulation 2022/1594 amending Regulation 765/2006.
closer coordination of Russian and Belarusian sanctions to ensure that Russian sanctions cannot be circumvented through Belarus;
extending the export ban to Belarus to a number of highly sensitive products and technologies that contribute to the military and technological strengthening of Belarus.
3 June 2022
Further restrictive measures against Belarus were adopted by Regulation 2022/877 amending Regulation 765/2006.
1 additional Belarusian bank has been removed from SWIFT.
The list of Belarusian entities subject to restrictions has been significantly widened (from 1 entity to 25). This is related to authorisations for the sale, supply, transfer or export of dual-use goods and technology, as well as goods and technology which might contribute to Belarus's military and technological enhancement, or to the development of its defence and security sector.
8 April 2022
Further restrictive measures against Belarus were adopted by Regulation 2022/577 amending Regulation 765/2006:
Prohibition on the sell, supply, transfer or export banknotes denominated in any official currency of a Member State to Belarus or to any natural or legal person, entity or body in Belarus, including the Government and the Central Bank of Belarus, or for use in Belarus; Art. 1za.
Prohibition to sell transferable securities denominated in any currency of an EU Member State issued after 12 April 2022, or units in collective investment undertakings providing exposure to such securities, to any Belarusian national or natural person resident in Belarus or to any legal person, entity or body established in Belarus; Art. 1y.
Road transport to Belarusian companies is prohibited, preventing them from transporting goods by road to the EU, including in transit. However, derogations are granted for a number of products such as pharmaceutical, medical, agricultural and food products, including wheat, and for road transport for humanitarian purposes; Art. 1zc.
9 March 2022
Regulation 2022/398 amending Regulation 765/2006 extended the extensive financial restrictive measures against Russia by analogy to Belarus. The following changes should be highlighted in particular:
The definition of "transferable security" has been amended to include cryptocurrencies; Article 1 (9).
Transactions related to the management of the reserves and assets of the Central Bank of Belarus are prohibited, including transactions with any legal person, entity or body acting on behalf of or at the direction of the Central Bank of Belarus (Article 1ja).
As from 12 April 2022, it is prohibited to list shares, as well as to provide services in relation thereto, on trading venues registered or recognised in the Union for transferable securities of any legal person, entity or body established in Belarus which is more than 50 % publicly owned; Art. 1jb.
It is prohibited to sell transferable securities denominated in euro issued after 12 April 2022, or units in collective investment undertakings providing exposure to such securities, to any Belarusian citizen or natural person resident in Belarus or to any legal person, entity or body established in Belarus; Art. 1jy.
Provision of public financing or public financial assistance for trade with or investment in Belarus is prohibited; Art. 1t), but with certain exceptions (binding financial commitments or financial assistance commitments entered into before 10 March 2022; provision of public financing or public financial assistance up to a total value of EUR 10,000,000 per project for the benefit of small and medium-sized enterprises established in the Union; provision of public financing or public financial assistance for trade in foodstuffs and for agricultural, medical or humanitarian purposes).
Exclusion of three Belarusian banks from the SWIFT system: Belagroprombank, Bank Dabrabyt and Development Bank of the Republic of Belarus; Art. 1zb
EU banks are not allowed to accept deposits from Belarusian citizens or natural persons residing in Belarus or entities established in Belarus if the total value of the credit balance per credit institution exceeds EUR 100,000.00; Art. 1u (1). This is accompanied by a reporting obligation on existing deposits above this amount; Art. 1z. Exemption applies to nationals of a Member State, a Member State of the European Economic Area or Switzerland, or to natural persons holding a temporary or permanent residence permit in a Member State, a Member State of the European Economic Area or Switzerland; Art. 1u (2). The prohibition shall also not apply to deposits which are necessary for the purpose of unannounced cross-border trade in goods and services between the Union and Belarus; Art. 1u (3).
Questions with regard to sanctions can be sent by email to [email protected].