The UK Government has introduced new economic, trade and transport sanctions on Belarus, extending existing Russia sanctions measures to Belarus in certain areas. These are included in The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 and entered into force on 5 July.

The main changes introduced by the relevant legislation include:

Expanded powers for designation, including:

Addition of power to designate persons by description

Expansion of criteria for designation to include:

  • conduct destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine, including by supporting or facilitating Russia’s actions in respect of Ukraine, in particular by providing logistical support to the Russian army, or by spreading disinformation about Russia’s invasion of Ukraine,
  • other actions undermining or threatening peace, security or stability in Europe; or
  • obtaining a benefit from / supporting the Government of Belarus through carrying on a relevant business activity, including carrying on business of economic significance – or in a sector of strategic significance – to the Government of Belarus.

Financial sanctions:

Existing restrictions on dealing with financial instruments and providing loans are extended to a broader range of transferable securities, money market instruments, loans and credit (effectively, capturing all Belarusian persons/entities beyond just state-owned entities, but with a carve out for Belarusian entities majority owned by non-Belarusian entities).

New prohibition on providing financial services for the purpose of foreign exchange reserve and asset management of the Central Bank of Belarus and the Ministry of Finance of Belarus and related persons.

Trade sanctions:

New export restrictions are imposed on goods and technology relating to critical industry, quantum computing and oil refining, and luxury goods, while prohibitions are widened in relation to dual-use goods and technology.

New import restrictions are imposed on mineral products (comprising a broader range of petroleum products), arms and related materiel, iron and steel.

A range of related trade activities are prohibited in respect of such controlled items, including technical assistance and funds/financial services relating to certain other prohibited trade activities, and enabling or facilitating military activities.

An existing prohibition on providing technical assistance to designated persons in relation to aircraft is widened to include technical assistance provided in relation to ships.

New aircraft and shipping sanctions:

It will now be an offence for certain Belarus-related aircraft to land in, or overfly, the UK, and for such aircraft to be registered in the UK.

There is now a prohibition on certain Belarus-related or other specified ships from entering UK ports or being registered in the UK. The Secretary of State has the power to direct the movement and detention of such ships.

Exceptions and licencing powers:

New exceptions in respect of the new trade provisions are included for travellers, diplomatic posts, international organisations, consumer communication devices and software, and for emergencies.

Two new general licences have been issued by OFSI to coincide with the new Belarus sanctions coming into force:

  • General Licence INT/2022/1976232 allows a period of until 04 August 2022 for a Person to provide financial services for the purpose of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 05 July 2022 involving: National Bank of Belarus (NBB); Ministry of Finance of Belarus (MF); and Those persons set out in regulation 15CA c to d of the Belarus Regulations.
  • General Licence INT/2022/1976332 allows for a 7-day wind down period in respect of, certain loans as well as transferable securities and money market instruments captured by the extended financial sanctions controls.

Tristan Grimmer is a partner in Baker McKenzie's London office and the UK Head of the International Trade Practice Group. He is also a member of the Compliance & Investigations and the International Trade and Competition practice groups. Tristan joined Baker McKenzie as a trainee in March 2004, qualifying in March 2006. He has advised on parallel investigations by authorities in the United States, Switzerland, Brazil and Japan, and has spent time working in Baker McKenzie's Chicago office. Tristan is named as a "Leading Individual" for EU And Competition: Trade, WTO Anti-Dumping and Customs in the UK Legal 500 2023 directory.


Ben Smith is a Partner in Baker McKenzie’s London office and a member of the firm’s Compliance & Investigations and International Trade practice groups. Both these practices are ranked Tier 1 by Legal 500 UK. Ben joined the London office of Baker & McKenzie in September 2007. He has also worked in Baker McKenzie's San Francisco and Brussels offices, as well as on secondment to the legal and compliance teams at three FTSE 100 UK plcs. The Legal 500 UK ranked Ben as a “Rising Star”, noting “Ben Smith is a pleasure to work with. Professional, knowledgeable and always ready to assist with practical solutions.”