The Council adopted restrictive measures targeting the Belarussian economy in view of the regime’s involvement in Russia’s illegal, unprovoked and unjustified war of aggression against Ukraine. These comprehensive measures aim at mirroring several of the restrictive measures already in place against Russia, and thereby address the issue of circumvention stemming from the high degree of integration existing between the Russian and Belarusian economies.
These sanctions affect multiple sectors, with some examples listed below. For comprehensive details on all the specific sanctions, please refer to the official legal text.
Export Ban Extension: Decision (CFSP) 2024/1864 extends the export ban on dual-use and advanced goods and technologies and introduces further restrictions on goods that could enhance Belarusian industrial capacities.
Transit Prohibition: To prevent circumvention, the decision bans the transit of dual-use goods and other specified technologies via Belarus.
Additional Export Restrictions: New restrictions on exports to Belarus, particularly for maritime navigation goods and luxury goods.
Diamond Ban: Prohibits the import, purchase, or transfer of Belarusian diamonds.
Mineral Products Ban: Extends the ban on mineral products to include crude oil and introduces an export ban on goods used in oil refining and natural gas liquefaction.
Crude Oil Transit Exception: Clarifies that the oil-related prohibitions do not affect the transit of crude oil from Russia through Belarus to EU member states.
Service Provision Ban: Prohibits certain services to Belarusian entities, including accounting, auditing, bookkeeping, tax consulting, and business consulting services.
Architectural, Engineering, IT, and Legal Services Ban: Prohibits the provision of architectural, engineering, IT consultancy, and legal advisory services to Belarus.
Advertising and Research Services Ban: Prohibits the provision of advertising, market research, public opinion polling, product testing, and technical inspection services to Belarus.
Firewall Derogation: Introduces exemptions for setting up a firewall to remove control exercised by listed persons over assets of non-listed entities.
Circumvention Clarification: Clarifies that circumvention includes both deliberate actions and those undertaken with awareness of potential circumvention effects.
Penalties Reporting: Requires member states to report penalties imposed for violations of the restrictive measures.
Document Confidentiality: Ensures documents concerning enforcement of restrictive measures are protected and kept confidential.
Revenue Diversification Ban: Introduces an import ban on goods that help Belarus diversify its revenue sources, such as coal.
Personal Effects Exception: Allows certain personal effects and specific circumstances for cars entering the Union.
Gold Ban: Prohibits the import, purchase, or transfer of gold from Belarus.
Energy and Aviation Restrictions: Imposes further restrictive measures in the energy and aviation sectors.
Transport Prohibition Extension: Extends transport bans on goods by Belarusian road transport undertakings and trailers in the Union.
Asset Freeze Criterion: Introduces additional criteria for listing persons or entities subject to asset freezes.
Information Sharing: Requires member states and the Commission to share information on measures taken and relevant details.
Temporary Derogations: Introduces temporary exemptions to facilitate divestment from Belarus by Union operators.
.Customs Goods Release: Provides rules on releasing goods subject to restrictive measures that were already in customs.
No-Reexport Clause: Requires exporters to contractually prohibit the re-exportation of sensitive goods to Belarus.
Clause Impact Assessment: Commission to assess the impact of the no-Belarus clause on preventing circumvention.
Due Diligence on Exportation: Requires Union operators to implement due diligence mechanisms to prevent re-exportation to Belarus.
Legal Person Compliance: Requires Union operators to ensure compliance with restrictions by entities they own or control outside the Union.
Machinery List Update: Amends the list of restricted machinery.
Compensation Claims: Allows Member State nationals and companies to claim compensation for damages caused by Belarusian entities.
Best Efforts Requirement: Requires Union operators to ensure their owned entities do not undermine restrictive measures.
Voluntary Disclosure: Allows for the consideration of self-disclosure when applying penalties for violations of restrictive measures.