EU imposes new sanctions against Belarus.

The EU has adopted a new sanctions package against Belarus, effective from 30 June 2024. These measures focus on certain service industries, trade and transport services.
EU imposes new sanctions against Belarus.

Expansion of Belarus sanctions

The Council of the European Union adopted new restrictive sanctions targeting the Belarusian economy over the Belarusian regime's involvement in Russia's war of aggression against Ukraine. These expanded sanctions run parallel to a number of sanctions already in place against Russia and have been in force since 30 June 2024.

The purpose of these new restrictive sanctions is to counter the circumvention of previously imposed restrictive sanctions due to the far-reaching integration between the Russian and Belarusian economies.

The new sanctions affect the following sectors:

  • Trade
  • Certain service industries
  • Transport services

Trade sanctions

The export ban in force on dual-use and advanced goods and technologies is extended. Further export restrictions are also introduced on goods that can contribute to strengthening Belarus' industrial capacity.

Further restrictions on exports to Belarus of marine and luxury goods and technologies are also introduced.

Regarding imports, it is now prohibited to (in)directly import, purchase or transfer gold, diamonds, helium, coal and mineral products from Belarus. This is additionally complemented by an export ban on goods and technologies for oil refining and natural gas liquefaction.

Service industry sanctions

The provision of certain services to Belarus, its government, state authorities, companies or agencies, and any natural or legal person acting on their behalf or under their direction is prohibited.

These service industries include:

  • Accounting services, auditing services (including statutory audits), accounting services, tax advisory services, and business and management consulting and public relations services;
  • Architectural and engineering services, IT consulting services and legal advisory services;
  • Advertising, market research and opinion polling services, and product testing and technical inspection services.

Transport sanctions

The ban on transporting goods by road, within the territory of the European Union with trailers and semi-trailers registered in Belarus, is extended.

To minimise the risk of circumvention of these sanctions, EU operators that are 25% or more owned by a Belarusian natural or legal person should be prohibited from becoming a road transport company or transporting goods by road within the Union, including in transit.

EU exporters to include no-Belarus clause in future contracts

The new sanctions require EU exporters to include the ‘no-Belarus clause’ in their future contracts. This contractually prohibits the re-export to Belarus or the re-export for use in Belarus of restricted goods.

The restricted goods are:

Exceptions for no-Belarus clause

The no-Belarus clause does not apply to:

  • Sales, supplies, transfers or exports to partner countries, as listed in Annex Vba of Regulation 765/2006 p. 188;
  • Contracts relating to goods falling under CN codes 8457 10, 8458 11, 8458 91, 8459 61, 8466 93;
  • Contracts concluded before 1 July 2024, until their expiry date;
  • Government contracts concluded with a public authority in a third country or with an international organisation;
  • Potential extension to non-EU subsidiaries.

Due diligence mechanism for EU operators to mitigate risks of re-exports to Russia

To counter the re-export of goods found on the battlefield in Ukraine or critical to the development of Russian military systems, EU operators selling these goods to third countries should have due diligence mechanisms in place that allow them to identify, assess and mitigate risks of re-exports to Russia.

Sanctions compliance and claims

EU parent companies must make every effort to prevent their non-European subsidiaries from engaging in activities that would circumvent the intended effects of the sanctions.

The package also includes sanctions that allow EU operators to claim compensation for any damage resulting from the implementation of the sanctions caused by Belarusian entities.

More information about the expansion of the Belarus sanctions

It is important to stay alert and make sure your trading activities are compliant with the new sanctions. Please refer to official publications for more detailed information:

Advice and support

Do you need help regarding the Belarus sanctions? For further guidance and support in navigating these new sanctions, Gaston Schul’s Consultancy & Advisory services are here to assist.