Sanctions On Belarus: Understanding The Impact And Implications

Belarus has been subject to sanctions from the US and the EU, with Switzerland also adopting sanctions against the country in 2024. The US has targeted individuals and entities with sanctions, including state-owned enterprises, government officials, and those facilitating sanctions evasion. The US has also imposed visa restrictions on certain individuals. The EU has adopted a new Belarus sanctions package, which includes export and import restrictions on various goods, restrictions on the provision of intellectual property rights and trade secrets, and prohibitions on the provision of certain business services and software to the Belarusian state.

US sanctions on Belarus

The US has imposed sanctions on Belarus, targeting individuals, entities, and aircraft with connections to the country. These sanctions are in response to Belarus's support for Russia's war in Ukraine, as well as human rights abuses and the erosion of democracy in Belarus. The US Department of the Treasury's Office of Foreign Assets Control (OFAC) has taken action against individuals, entities, and organisations involved in supporting Russia's military and defence activities, as well as those involved in revenue generation for Belarusian oligarchs and the Lukashenka regime.

On November 14, 2024, the US Department of the Treasury announced that OFAC was taking action against 19 individuals, 14 entities, and one aircraft pursuant to Belarus-related Executive Order (E.O.) 14038. This includes persons involved in military resource production, the transshipment of goods to Russia, sanctions evasion, and revenue generation for Belarusian oligarchs connected to Alyaksandr Lukashenka. OFAC concurrently designated five targets—three individuals and two entities—under Russia-related E.O. 14024.

The US has targeted individuals and entities that provide support to Russia's military and defence activities. For example, OFAC designated Belarusian manufacturers LLC AlYurTekh, ALC Diskoms, LLC MOT, LLC Grosver Grup, and Limited Liability Company Tochnaya Mekhanika for providing financial, material, or technological support to Peleng JSC (Peleng), a leading design enterprise in Belarus's optoelectronic industry that produces components for military equipment.

In addition, the US has imposed sanctions on cargo airline companies that provide transportation services for Russian military personnel and equipment. For instance, OFAC designated Aviakompaniya Rada LLC and UE RubiStar, two private Belarusian cargo airline companies, for their involvement in the transportation of military supplies and personnel.

The US has also targeted logistics companies that facilitate the re-export of goods, including machinery and hydrocarbons, to Russia. Ruzekspeditsiya LLC and VLATE Logistic LLC, two Belarus-based logistics entities, were designated by OFAC for their connections to Belarusian oligarchs and their role in generating revenue for the Lukashenka regime.

Furthermore, the US has taken action against defence sector entities that supply ammunition and equipment to the Belarusian and Russian armed forces. Joint Stock Company Plant Legmash, a Belarus-based manufacturing plant, was designated for shifting its operations to produce artillery ammunition. KB Unmanned Helicopters, a Belarusian unmanned aerial vehicle (UAV) developer and manufacturer, was also sanctioned for producing drones for the security and defence sectors.

The US has also identified and blocked property belonging to Lukashenka, including aircraft in the presidential fleet, such as the Boeing 767-32K(ER) with the tail number EW-001PB.

EU sanctions on Belarus

The EU has imposed several sanctions on Belarus in response to the country's political situation and its role in the Russia-Ukraine conflict. These sanctions aim to hold the Lukashenka regime accountable for its actions and undermine its ability to operate.

On August 9, 2021, the US Department of State issued an executive order blocking the property of additional persons contributing to the situation in Belarus. This was followed by a joint statement on June 21, 2021, by the Treasury and international partners, condemning ongoing human rights abuses and the erosion of democracy in Belarus.

Specific sanctions include the designation of Belarusian networks, targeting revenue generators for the Lukashenka regime, human rights abuses, and their role in Russia's war machine. There are also visa restrictions on regime members and sanctions on state-owned enterprises and government officials. The US has also taken action against Belarusian military support for Russia, including tightening sanctions and urging increased vigilance for potential export control evasion attempts.

The legal framework for these sanctions includes Executive Orders 14038 and 13405, the International Emergency Economic Powers Act (IEEPA), and the National Emergencies Act (NEA). These are further codified in the Belarus Sanctions Regulations within the Code of Federal Regulations.

To ensure compliance with the sanctions, the Office of Foreign Assets Control (OFAC) provides interpretive guidance and licenses for specific activities. General licenses authorise activities that would otherwise be prohibited, such as transactions related to civil aviation safety and the wind-down of transactions with certain entities.

Swiss sanctions on Belarus

Switzerland has imposed sanctions on Belarus, including financial sanctions and travel bans on 15 individuals, including President Alexander Lukashenko and his son and national security advisor, Viktor Lukashenko. The sanctions were implemented in response to the violent crackdown and arbitrary arrests following the contested 2020 presidential elections in Belarus.

The Swiss Federal Council announced the sanctions on 11 December 2020, and they came into force that same day at 6 pm. The individuals subject to the sanctions are banned from entering or travelling through Switzerland, and their assets are to be frozen and reported to the Swiss State Secretariat for Economic Affairs (SECO) without delay.

In addition to the individual sanctions, Switzerland also amended its Ordinance on Measures against Belarus to include an embargo on armaments and goods that could be used for internal repression. This move mirrors similar actions taken by the European Union (EU) in November 2020 and is a response to the ongoing repression of civil society and opposition groups in Belarus.

Switzerland's decision to impose sanctions on Belarus is in line with the EU's actions and demonstrates its concern over the situation in the country. The Swiss government has urged Belarus to respect its international human rights obligations and engage in dialogue with civil society to resolve the ongoing tensions.

US visa restrictions on Belarus

On February 28, 2022, the Department of State ordered the departure of US government employees and the suspension of operations at the US Embassy in Minsk. All consular services have been suspended until further notice, and US citizens in Belarus requiring consular services are advised to leave the country as soon as possible and contact a US embassy or consulate in another country.

The US has advised its citizens against traveling to Belarus due to the facilitation of Russia's war against Ukraine, the arbitrary enforcement of local laws, the potential for civil unrest, and the risk of detention. There is also a risk of harassment specifically targeted at foreigners. US citizens in Belarus are strongly advised to depart immediately.

US citizens who choose to travel to Belarus despite the warnings must have a valid visa issued by a Belarusian embassy or consulate overseas. However, even with a visa, entry into Belarus over a land border is highly unlikely. The same applies when exiting the country. US citizens are advised to enter and exit Belarus by air, as regulations regarding travel between Russia and Belarus can change unexpectedly.

All US citizens staying in Belarus for more than five days, excluding Sundays and national holidays, are required to register with the local office of the Citizenship and Migration Department of the Ministry of Interior. This requirement applies to both visa holders and those who enter under the 30-day visa-free regime. Registration must be completed within five days of arrival, excluding Sundays and national holidays. Failure to register or remaining in Belarus for more than 30 days can result in administrative action, including fines, deportation, and future entry bans.

US sanctions on individuals and entities

The US has imposed sanctions on various Belarusian individuals and entities, targeting those contributing to the situation in Belarus and undermining its democratic processes and institutions. These sanctions are implemented through the Office of Foreign Assets Control (OFAC) and are based on executive orders and public laws passed by Congress.

On March 24, 2023, the US Treasury sanctioned three Belarusian state-linked entities and nine individuals, including directors of two major automotive companies, in response to the crackdown on pro-democracy activists following the disputed 2020 presidential election. The sanctioned entities include the Belarusian Automobile Plant and the Minsk Automobile Plant, which were significant sources of revenue for the Lukashenka regime. The US also identified a US-made Boeing 737 jet as the property of Belarusian leader Alexander Lukashenko, effectively blocking its use in the country.

The US Treasury also imposed sanctions on seven members of Belarus' central election commission and the commission itself. Additionally, visa restrictions were put in place for 14 individuals, including regime officials, to mark Belarusian Freedom Day, an unofficial holiday commemorating the country's independence from the Russian empire.

These sanctions generally prohibit Americans from conducting business with the designated entities and individuals and can result in similar measures against financial institutions or persons who transact with them. The US has continued to take action against the Lukashenka regime, targeting its military support for Russia, human rights abuses, and acts of repression.

The US government has also issued general licenses, authorizing specific activities and transactions that would otherwise be prohibited under the sanctions. These licenses are granted in the interest of US citizens or to allow for wind-down operations and civil aviation safety.

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