(P) GB Businesses need to exercise due diligence to prevent trading with sanction entities or persons. Make sure you know these rules when trading with Belarus, late updated 23.03.2022
Licences Revoked
Further to Belarus’s involvement in Russia’s aggression against Ukraine, the Export Control Joint Unit (ECJU) has re-assessed relevant open general export licences against the Strategic Export Licensing Criteria. Consequently, Belarus has been removed as a permitted destination from 9 open general export licences.
The affected licences are:
open general export licence (chemicals)
open general export licence (chemicals) from December 2019
open general's export licence (cryptographic development)
open general export licence (cryptographic development) from December 2019
open general export licence (export after the exhibition: dual-use items)
open general export licence (export for repair/replacement under warranty: dual-use items)
open general export licence (export for repair/replacement under warranty: dual-use items) from December 2019
open general export licence (X)
open general export licence (X) - from December 2019
Sanctions imposed
The UK has imposed a package of trade, financial, and aviation sanctions on Belarus, in response to the continued undermining of democracy and human rights violations by the Lukashenko regime.
These measures coincided with the anniversary of the fraudulent election in Belarus coincided with the US and Canada's announcement of their own packages of measures and followed the EU’s measures announced on 24th June.
Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2021
The new measures put in place by the Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2021 are as follows:
Trade sanctions
Prohibition on the provision of technical assistance related to aircraft where this is provided to or for the benefit of specific designated persons. The statutory guidance has been updated to identify specific aircraft that HMG considers relevant to this prohibition, and the UK Sanctions List has been updated to identify those designated persons to whom this prohibition relates (in the ‘Sanctions Imposed’ field).
Prohibition on the import, acquisition and supply/delivery of potash originating in or consigned from Belarus.
Prohibition on the import, acquisition and supply/delivery of petroleum products originating in or consigned from Belarus, as well as related provision of technical assistance, financial services, funds and brokering services.
Prohibition on the export, making available, supply/delivery or transfer of items that could be used for the interception or monitoring of telecommunications in Belarus, as well as related provision of technical assistance, financial services, funds and brokering services. This prohibition also covers the provision of interception and monitoring services to or for the benefit of the Government of Belarus.
Prohibition on the export, making available or supply/delivery of items used in the manufacture of cigarettes.
Prohibition on the export, making available, supply/delivery or transfer of dual-use items where they are for military use or military end-users, as well as related provision of technical assistance, financial services, funds and brokering services.
The statutory guidance has also been amended to remove licensing grounds from the existing arms embargo related to biathlon rifles, and .22 calibre firearms.
Financial sanctions
Prohibition on dealing with transferable securities and money-market instruments with a maturity exceeding 90 days issued after 1200 on 9th August 2021, by or on behalf of Belarus, a Belarusian authority, credit or financial institutions which are majority-owned by Belarus or a Belarusian authority, as well as various categories of entities owned by them or acting at their behalf/direction. Prohibition on granting loans to the above entities.
Prohibition on providing insurance and reinsurance to Belarus, a Belarusian authority, as well as various categories of entities owned by them or acting at their behalf/direction.
Aviation sanctions
A provision allowing the Secretary of State to direct the Civil Aviation Authority to refuse, suspend or revoke permissions in respect of Belarusian aircraft. A provision allowing air traffic control to direct Belarusian aircraft not to overfly the UK, allowing an airport operator to direct Belarusian aircraft not to land at an airport, and allowing the Secretary of State to direct air traffic control and airport operators accordingly.
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