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Notice to exporters 2021/09: new UK trade sanctions on Belarus
New trade sanctions measures imposed on the Republic of Belarus following amendments to the UK’s Belarus Sanctions Regulations.
This notice provides an overview of the new trade sanctions measures imposed on Belarus, which are administered by the Export Control Joint Unit ( ECJU). It should be read alongside the Belarus Statutory guidance published by the Foreign, Commonwealth and Development Office ( FCDO).
These measures are subject to exceptions. You may be able to obtain licences in certain circumstances.
The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (“Belarus Sanctions Regulations”) came fully into force on 31 December 2019.
The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2021(“the Belarus Sanctions Amendment Regulations”), which came into force at 12pm on 9 August 2021, have amended the Belarus Sanctions Regulations to impose a package of trade, financial and aviation sanctions on Belarus. This is in response to the continued undermining of democracy and human rights violations by the Lukashenko regime. These measures coincide with the anniversary of the fraudulent election in Belarus, and are imposed in coordination with international partners. They follow the EU’s measures announced on the 24 June 2021.
New trade sanctions
The Belarus Sanctions Amendment Regulations impose new trade sanctions measures some of which are administered by ECJU.
These measures cover:
the export, making available, supply and delivery or transfer of items that could be used for the interception or monitoring of telecommunications (as specified in Schedule 2A to the Belarus Sanctions Amendment Regulations) in Belarus, as well as related provision of technical assistance, financial services, funds and brokering services. This prohibition also covers interception and monitoring services to, or for the benefit of, the Government of Belarus
the export, making available, supply and 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 acquisition or supply and delivery of potash (as specified in Schedule 2B to the Belarus Sanctions Amendment Regulations) originating in or consigned from Belarus
the acquisition or supply and delivery of petroleum products (as specified in Schedule 2B to the Belarus Sanctions Amendment Regulations) originating in or consigned from Belarus, as well as provision of technical assistance, financial services, funds and brokering services related to acquisition or supply and delivery of these items
the export, making available or supply and delivery of specified goods used for the production or manufacture of tobacco industry products (as specified in Schedule 2B to the Belarus Sanctions Amendment Regulations) to or for use in Belarus
the provision of technical assistance related to aircraft where this is provided to or for the benefit of specific designated persons. The Belarus Statutory guidance has been updated to identify specific aircraft that Her Majesty’s Government 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)
the removal of the exception to the existing arms embargo related to biathlon rifles, and .22 calibre firearms. The Belarus Statutory guidance has been amended to remove the licensing grounds related to biathlon rifles, and .22 calibre firearms
Exceptions and licensing
The trade sanctions measures listed above are subject to exceptions, and you may be able to obtain licences in certain circumstances.
Regulation 31 and 31C of the Belarus Sanctions Regulations (as amended) set out the exceptions to some of the trade sanctions prohibitions which apply within certain defined circumstances. An exception applies automatically and does not require you to obtain a licence issued in accordance with the Regulations.
The specific circumstances in which a licence may be granted for certain trade activities that would otherwise be prohibited by the Regulations are set out in the Belarus Statutory guidance.
Licence applications related to export controls and trade sanctions implemented by ECJUcan be made through ECJU’s online export licensing system SPIRE. You must create an account on SPIRE before you can apply. You should note the activities you wish to cover and specify the regulation that applies.
Trade sanctions related to import of goods into the UK are administered by DIT’s Import Licensing Branch. See notice to Importers for information on the new import-related measures imposed on Belarus.