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UN Sanctions

There is no UN sanctions regime against Belarus.

EU Sanctions

The EU sanctions regime against Belarus is based on "COUNCIL DECISION 2012/642/CFSP of 15 October 2012 concerning restrictive measures against Belarus."

Belarus sanctions are regime-based sanctions consisting of the following restrictive measure:

  • Travel bans 

  • Financial sanctions (asset freezing)

  • Arms embargo

  • Trade sanctions on certain goods 

It is notable that the EU ramped up its sanctions against Belarus on two occasions: first, after the forced landing of a Ryanair flight in Minsk, Belarus, on 23 May 2021, and then, following Russia's invasion of Ukraine in February 2022, supported by the Belarusian Government. ​The new sanctions measures include expanded export controls, restrictions on access to the EU's capital markets, prohibition on the importation of Belarussian petroleum products and potash, prohibition on the provision of insurance to the Belarusian Government, prohibition on the importation of wood, cement, iron, steel, and rubber products, prohibition on certain transactions related to the Central Bank of Belarus, prohibition on the provision of public financing, prohibition on the acceptance of deposits from Belarusian persons exceeding EUR 100,000, prohibition related to transportation, and several additional blocking sanctions against individuals or entities. 

U.S. Sanctions

The Belarus sanctions program is a list-based program and it was established in 2006 following the issuance of  E.O. 13304.

As stated in the E.O. a national emergency is declared to address the following: 

"The actions and policies of certain members of the Government of Belarus and other persons to undermine Belarus’ democratic processes or institutions, manifested most recently in the fundamentally undemocratic March 2006 elections, to commit human rights abuses related to political repression, including detentions and disappearances, and to engage in public corruption, including by diverting or misusing Belarusian public assets or by misusing public authority"

The criteria to be listed under this program could be found at 31 C.F.R. §548.201.

Those listed under this program in the SDN list carry the tag of [BELARUS]​. OFAC recently added a number of individuals following the controversial presidential elections in Belarus. 

On August 9, 2021, the President of the United States issued a new Executive Order (E.O. 14038) and expanded the scope of the existing national emergency in response to the Belarusian regime’s harmful activities and long-standing abuses aimed at suppressing democracy and the exercise of human rights and fundamental freedoms in Belarus. The new E.O. provided several additional designation grounds. On December 2, 2021, OFAC issued a determination and imposed debt-restriction type of sanctions on the Ministry of Finance of the Republic of Belarus and the Development Bank of the Republic of Belarus.  Pursuant to this new restriction, U.S. persons may not deal with debt longer than 90 days issued by the named Belarusian entities.

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