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Sanctions - Belarus

Overview

Belarus has been subject to targeted restrictive measures from European and international partners since the mid-2000s. The scope of those measures expanded substantially after the presidential election of August 2020, which the international community refused to recognise.

From February 2022 onwards, the Lukashenka regime's active facilitation of Russia's invasion of Ukraine has resulted in a third, overlapping sanctions regime.

The Belarus sanctions regime of the EU targets over 250 individuals and more than 40 entities, the UK over 150 individuals and entities, and the US over 100 individuals and entities. The sanctions extend to a number of significant bulk trade commodities and sectors, most notably potassium chloride (potash), petroleum products, tobacco products, and – most recently – coal and other mineral products. Carriage of military goods, dual-use goods, monitoring technology and aircraft parts is also prohibited. Belaruskali, designated by both the US and UK, remains one of the largest potash producers in the world, accounting for approximately 20% of global supply.

Member Advisory

Members should check all parties to a voyage – including the charterer, shipper, physical supplier, consignee, receiver, local agents, banks and cargo insurers – against the lists of specially designated nationals (SDNs) and prohibited activities before undertaking any trade with Belarus or involving Belarusian individuals or entities. Regardless of a Member's operational or flag state, trading with or on behalf of an SDN, or breaching a sanctioned trade, may result in severe civil and criminal penalties and possible loss of insurance cover.

European Union

The EU Belarus sanctions regime is one of the longest-standing autonomous EU restrictive measures programmes, with initial measures dating to 2004 (EU Common Position 2004/661/CFSP). The current legal framework is anchored in:

  • Council Regulation (EC) No 765/2006 of 18 May 2006 - the operative regulation, directly binding on all EU Member States and all EU natural and legal persons. The consolidated text (most recently updated 17 December 2025) is available on EUR-Lex and is the authoritative reference.
  • Council Decision 2012/642/CFSP of 15 October 2012 - the CFSP framework decision, setting out designation criteria, the arms embargo, and ancillary measures. The consolidated text (most recently updated 20 July 2025) is available on EUR-Lex.

The sanctions regime is subject to periodic renewal. The current measures are in force until 28 February 2026 and are expected to be renewed.

New tariffs on Belarusian agricultural goods and fertilisers have applied since 1 July 2025 under a separate Council regulation.

Prohibitions

Asset Freeze

Article 2 of consolidated Regulation (EC) No 765/2006 provides:

  • All funds and economic resources belonging to, owned, held, or controlled by persons listed in Annex I shall be frozen.
  • No funds or economic resources shall be made available, directly or indirectly, to or for the benefit of listed persons or entities.
  • Knowing and intentional participation in activities the object or effect of which is to circumvent the asset freeze directly or indirectly is prohibited.

Arms Embargo and Internal Repression Equipment

  • Prohibition on the sale, supply, transfer, or export directly or indirectly of arms and equipment that might be used for internal repression (as listed in Annex III to the Regulation), including firearms, ammunition, riot control equipment, and related technology.
  • Prohibition on providing technical assistance, financial assistance, or brokering services in connection with such equipment.
  • Ban on the sale, supply, transfer, or export of firearms, parts, essential components, and ammunition as listed in Annex I to Regulation (EU) 2025/41 (implementing the UN Firearms Protocol) and Annex XVI to Regulation (EC) No 765/2006 to any person in Belarus or for use in Belarus.

Dual-Use and Defence Sector Export Restrictions

  • Prohibition on the sale, supply, transfer, or export of dual-use goods and technology (as listed in the EU Dual-Use Regulation) to any military end-user or for military use in Belarus.
  • From February 2025 (Decision 2025/391): expanded restrictions on goods and technology that might contribute to enhancing Belarus's defence and security sector, mirroring equivalent Russia measures.
  • Prohibition on providing technical assistance, brokering services, or financing related to dual-use or defence-related goods.

Telecommunications and Surveillance

  • Prohibition on providing any telecommunication or internet monitoring or interception services to, or for use by, the Belarusian state or its agencies.
  • Prohibition on the sale, supply, transfer, or export of equipment capable of being used for internet or telephone monitoring or interception.

Trade - Tobacco Products

  • Prohibition on the sale, supply, transfer, or export of goods used for the production or manufacturing of tobacco products to Belarus.

Trade - Petroleum Products

  • Prohibition on the import of petroleum products into the EU if they originate in or have been exported from Belarus.
  • Prohibition on purchasing petroleum products located in or originating in Belarus.
  • Prohibition on transporting such petroleum products.

Trade - Potassium Chloride (Potash)

Pursuant to Article 1g of consolidated Regulation (EC) No 765/2006, the following are prohibited:

  • Importing, purchasing, or transferring, directly or indirectly, potassium chloride ('potash') products from Belarus, whether or not originating in Belarus.
  • The CN codes for prohibited potash products covered by the Regulation include products falling under the following headings: CN 3104 20 (potassium chloride), CN 3104 90, CN 3105 20, CN 3105 40, CN 3105 51, CN 3105 59, CN 3105 90, CN 2620 60, and related sub-headings as specified in the annex to the Regulation.

Belaruskali OAO remains one of the world's largest potash producers, accounting for approximately 20% of global supply. Belaruskali is designated by both the US and UK. EU sanctions on Belarusian potash remain in force regardless of US GL13 (see Section 3.4).

The CN codes for prohibited potash products under the Regulation are as follows:

asdad

Trade - Coal and Other Mineral Products (from June/July 2024)

  • Prohibition on importing, purchasing, or transferring gold, diamonds, helium, coal, and other mineral products — including crude oil from Belarus.
  • This prohibition was introduced by the June 2024 package (effective 1 July 2024) and represents a significant additional trade restriction not present in earlier packages.

Luxury Goods

  • Prohibition on selling, supplying, or transferring luxury goods above specified threshold values to any natural person in Belarus or for use in Belarus.

Financial Messaging Services (from July 2025)

Anti-Circumvention Obligations

  • Article 8g: EU operators selling common high-priority items to third countries are required to include a contractual 'no re-export to Belarus' clause and to implement due diligence capable of identifying circumvention risks. This obligation applies from 2 January 2025.
  • Article 8i ('best efforts' obligation): EU individuals, companies, and entities that own or control non-EU entities are required to use their best efforts to ensure those non-EU entities do not engage in activities that undermine the Belarus or Russia sanctions regimes. This obligation applies across both regimes.

Relevant Resources

EU Sanctions Map (searchable interactive tool)
EU Council: Sanctions Against Belarus (main page)
EU Council: Timeline of Sanctions Against Belarus
EUR-Lex Summary: Restrictive Measures Against Belarus

United Kingdom

The UK's Belarus sanctions regime is established under the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/600), which came into force on 31 December 2020 and were made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018). These Regulations transposed, with substantially the same effect, the EU Belarus sanctions regime as it stood at the time of the UK's departure from the EU.

They have been most recently by the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024 (S.I. 2024/1157) (effective 5 December 2024), which strengthened OFSI's enforcement powers, intelligence-gathering capacities, and licensing procedures.

As of 28 January 2026, the UK Sanctions List (UKSL), published by the FCDO, is the sole authoritative source for all UK Belarus sanctions designations. The OFSI Consolidated List of Asset Freeze Targets has been closed and is no longer updated. From 28 January 2026, all sanctions compliance screening must use the UK Sanctions List and its associated search tool on GOV.UK.

Prohibitions

Asset Freeze - Financial Sanctions

It is prohibited for any UK person, or any person within the UK, to:

  • Deal with funds or economic resources owned, held, or controlled by a designated person.
  • Make funds or economic resources available, directly or indirectly, to or for the benefit of a designated person.
  • Circumvent, participate in activities to circumvent, or attempt to circumvent any financial prohibition.

Military Goods and Technology

  • Prohibition on the export, supply, delivery, or making available, directly or indirectly, of military goods (as specified in Schedule 1 to the Regulations) to Belarus, or for use in Belarus, including arms, military vehicles, and associated equipment.
  • Prohibition on providing technical assistance, brokering services, or financial services in connection with military goods.

Dual-Use Goods and Technology

  • Prohibition on the export, supply, delivery, or making available of dual-use goods and technology (as listed under UK domestic dual-use controls) to any military end-user or entity in Belarus, or for military use in Belarus.
  • Prohibition on providing related technical assistance, brokering services, or financing.

Internal Repression Goods and Technology

  • Prohibition on the export, supply, or delivery of goods or technology capable of being used for internal repression in Belarus (including crowd control equipment, armoured vehicles, surveillance systems, and associated items listed in Schedule 3).
  • Prohibition on providing related technical assistance, financing, or brokering services.

Interception and Monitoring Goods, Technology, and Services

  • Prohibition on the export or supply of goods, technology, or software capable of being used to intercept or monitor telephone or internet communications in Belarus.
  • Prohibition on the provision of interception or monitoring services to, or for use by, the Belarusian state or its agencies.

Tobacco Industry Goods

  • Prohibition on the export, supply, or delivery of goods used for the production or manufacturing of tobacco products to any person in Belarus or for use in Belarus.

Potash

  • Prohibition on the import, purchase, or transfer, directly or indirectly, of potassium chloride products ('potash') consigned from or originating in Belarus.

Belaruskali OAO is designated under UK sanctions. Dealings with Belaruskali or entities owned 50% or more by Belaruskali are prohibited regardless of a US GL13 (see Section 3.4).

Petroleum Products

  • Prohibition on the import, purchase, or transfer of petroleum products consigned from or originating in Belarus, or located in Belarus.
  • Prohibition on transporting such petroleum products to or within the UK.

Transit Through the United Kingdom

  • The transit and transhipment exception under Article 17 of the Export Control Order 2008 does not apply to goods destined for Belarus. A licence is required for any goods transiting the UK or being transhipped in the UK with a view to re-exportation to Belarus.

Relevant Resources

UK Sanctions List (sole authoritative source from 28 January 2026)
Republic of Belarus Sanctions: Statutory Guidance

United States

US sanctions against Belarus are administered by the Office of Foreign Assets Control (OFAC) within the US Department of the Treasury. The regime is underpinned by two Executive Orders and the Belarus Sanctions Regulations (BSR) codified at 31 CFR Part 548:

  • Executive Order 13405 of 16 June 2006 - the foundational instrument; authorises the blocking of property of persons determined to undermine democratic processes or institutions in Belarus.
  • Executive Order 14038 of 9 August 2021 - substantially expanded the regime following the fraudulent 2020 Belarusian presidential election; authorised designation of any person operating or having operated in the defence and related materiel sector, the security sector, the energy sector, the potash sector, the tobacco products sector, the construction sector, or the transportation sector of the Belarusian economy.

OFAC has explicitly warned that foreign financial institutions risk designation for conducting or facilitating significant transactions involving persons blocked pursuant to E.O. 14038 or the related Russia E.O. 14024. A number of Belarusian individuals and entities are dual-listed under both orders.

Prohibitions

Asset Blocking

All property and interests in property of any SDN that are in the United States, or that come within the United States or the possession or control of any US person, are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in. The 50% rule applies: entities owned or controlled 50% or more by one or more blocked persons are blocked regardless of whether separately listed.

Sectoral Designation Risk (E.O. 14038)

E.O. 14038 provides for the designation of any person determined to operate or have operated in the following sectors of the Belarusian economy:

  • Defence and related materiel sector.
  • Security sector.
  • Energy sector (including petroleum, petroleum products, and potash).
  • Potash sector: includes production, distribution, and trade of potassium chloride and related mineral fertilisers.
  • Tobacco products sector.
  • Construction sector.
  • Transportation sector.

Operation in these sectors does not automatically result in designation, but represents a defined risk for non-US persons engaging in such activities that involves Belarusian parties.

Partial sanctions relief - potash sector (December 2025): On 15 December 2025, OFAC issued General License 13 (GL13). GL13 authorises transactions involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, and Belaruskali OAO — entities previously designated under the Belarus Sanctions Regulations (31 CFR Part 548).

Note on GL13 practical effect: EU sanctions on Belarusian potash remain in force and Lithuania has maintained its refusal to allow Belarusian potash transit via Klaipeda port. These constraints substantially limit the commercial impact of GL13 for global market access.

Secondary Sanctions Risk for Non-US Persons

OFAC has stated that non-US persons who materially assist or facilitate transactions on behalf of designated Belarusian persons, or who provide significant financial, material, or technological support for such persons, risk designation themselves under E.O. 14038. This includes foreign financial institutions conducting significant transactions involving SDNs designated under E.O. 14038 or the parallel Russia E.O. 14024.

Members are strongly advised to avoid all trades involving any designated entity or any entity which is more than 50% owned by a designated entity.

Relevant Resources

OFAC Belarus Sanctions (main page)
SDN List Search (select programmes: BELARUS and BELARUS-EO14038)
Belarus Sanctions FAQ Topic Page
31 CFR Part 548 — Belarus Sanctions Regulations

Important note

The information provided by the Club and in particular through its website is not and is not intended to be exhaustive. Every effort is made to ensure the accuracy of the information provided. However this cannot be guaranteed given that sanctions measures are subject to alteration by governmental organisations at short notice. Further the information on this site is not, and should not be relied upon as, independent legal advice.

Members are strongly advised to undertake due diligence before fixing any business to or from a sanctioned country in order to ensure that neither the prospective cargo nor the parties to the planned venture are sanctioned. The Club is willing to assist Members where possible but they may nevertheless wish to take independent legal advice.