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Belarus

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Following coordinated designations of certain Belarusian individuals and entities earlier this week (see our previous post here), the EU has announced that further sector-based economic sanctions will come into force on 25 June 2021. The restrictions are implemented by Council Regulation (EU) 2021/1030 (the “Regulation“), which amends Regulation (EC) No 765/2006. The new sanctions target a broad range of technology and software, dual-use goods and technology, tobacco, petroleum and potash products, and financial services. The prohibitions apply regardless of…

Effective June 21, 2021, the Government of Canada imposed new sanctions against 17 individuals and 5 entities under the Special Economic Measures (Belarus) Regulations (the “Regulations”). The sanctions were imposed in response to alleged systemic human rights violations and the May 23, 2021 diversion, by the Belarusian regime, of Ryanair Flight 4978 from its planned course in order to land in Minsk. The imposition of sanctions by the Government of Canada was taken in coordination with the…

On May 28, 2021, the Biden Administration issued a press release confirming the re-imposition of sanctions on certain Belarusian state-owned enterprises (SOEs) (presaged by the issuance of wind down Belarus General License 2H on April 19, 2021) and suspending the application of the 2019 US-Belarus Air Services Agreement (“2019 USB Agreement”) in response to the Belarusian government’s apparent forced diversion of a commercial flight to Minsk on May 23. The Press Release also indicates additional sanctions targeting Belarusian government…

On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (SDNs), and entities in which they own a 50 percent or greater interest. The revocation of GL 2G effectively strengthens US sanctions against Belarus, and may make it more difficult for US Persons to conduct…

On 12 March 2021, the Official Journal published Commission Implementing Regulation (EU) 2021/442 of 11 March 2021 making the exportation of certain products subject to the production of an export authorisation, which requires an export authorisation to export (or re-export after such goods have been subject to manufacturing operations including filling and packaging within the customs territory of the Union) vaccines against SARS-related coronaviruses (SARS-CoV species) currently falling under CN code 3002 20 10, irrespective of their packaging…

On 11 December, the Swiss Federal Council extended sanctions against Belarus. Financial sanctions and travel bans were imposed on 15 individuals, including President Alexander Lukashenko. The new measures entered into force at 6pm on 11 December. The sanctions are in line with the decisions taken by the EU on 6 November 2020. The 15 persons newly added to the list in Annex 1 to the Ordinance on Measures against Belarus are alleged to be responsible…

On 29 September 2020, the Office of Financial Sanctions Implementation announced that 8 Belarusian officials, including Alexander Lukashenko, his son Victor, and other senior Belarusian government officials, have been subjected to sanctions (asset freezes and travel bans) under the UK’s autonomous Global Human Rights sanctions regime. This regime was introduced earlier in 2020 as a “Magnitsky-style” regime, and is the first autonomous sanctions regime adopted by the UK following its departure from the EU. For…