On 9 June 2023, the UK implemented The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2023 which amends The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (the “Belarus Regulations”). The latest approach allows the UK government to more strongly target exports from Belarus and to ramp up restrictions against Belarus to avoid any circumventions of restrictions against Russia via Belarus.
This post sets out a brief summary of the key points:
Imports & Exports
Chapter 2 of the Belarus Regulations has been significantly expanded. It is now prohibited to export, amongst other things, bank notes denominated in sterling or the currency of any EU member state, chemical and biological weapons related goods & technology and machinery related goods & technology to Belarus.
Chapter 2B of the Belarus Regulations has also been expanded such that UK persons are now prohibited from engaging in transactions relating to, amongst others, cement, gold & gold jewellery, processed gold, rubber & wood from Belarus or of Belarus origin, irrespective of the destination of such products.
Accompanying schedules have also been added to the Belarus Regulations which list the HS Codes of the products that are now subject to the restrictions.
The latest amendment also imposes a new Chapter 2D which is related to internet services. Any persons provide an internet access service must take reasonable steps to prevent a UK user from accessing any internet services provided by a designated person in Belarus. OFCOM has been given the power to fine persons they believe have failed to perform their duties under this amendment.
Designated Person Criteria
Similar to the latest amendments to the restrictions relating to Russia, the criteria of “involved person” under regulation 6 of the Belarus Regulations has been expanded to include a wide range of persons who work for or are affiliated to the Government of Belarus and immediate family members associated with designated persons.