Belarus Sanctions Lawyers
Belarus is subject to targeted U.S. sanctions administered by OFAC under Executive Order 13405, targeting the Lukashenko government, state enterprises, and human rights violators. Our lawyers advise businesses and individuals on Belarus sanctions compliance and SDN list removal.
Belarus sanctions are targeted U.S. sanctions administered by OFAC under Executive Order 13405 and EO 14038, directed at the Lukashenko government, Belneftekhim (state petrochemical company), and individuals responsible for human rights violations following the disputed 2020 elections. Belarus is NOT a comprehensively sanctioned country — transactions are generally permitted unless involving designated parties.
Belarus OFAC Sanctions Overview
Belarus sanctions target specific government officials, state enterprises, and sectors — not the entire Belarusian economy. This distinguishes Belarus from comprehensively sanctioned countries like Iran or Cuba. However, EU and UK sanctions on Belarus are significantly broader than U.S. OFAC sanctions.
Belarus Sanctions vs. Comprehensive Sanctions — Key Differences
| Factor | Belarus (Targeted) | Iran/Cuba (Comprehensive) |
|---|---|---|
| Scope | Specific persons, entities, sectors | Virtually all transactions prohibited |
| Trade | Permitted unless with SDN-listed parties | Requires OFAC license for any trade |
| USD Transactions | Permitted with non-designated parties | Prohibited for all transactions |
| U.S. Investment | New investment restricted under EO 14038 | Fully prohibited |
| EU/UK Sanctions | Much broader — sector restrictions on potash, oil, financial | Also broad |
| Banking Risk | High — correspondent banks apply EDD | Extremely high — most banks refuse |
Key Designated Belarusian Entities
- Belneftekhim — state petrochemical company, along with all subsidiaries and affiliates
- Lukashenko government officials — president, ministers, security service personnel
- State security services — KGB Belarus and related entities
- State media — various Belarusian state broadcasters and publications
What Transactions Are Restricted?
- Any transaction with SDN-listed Belarusian individuals or entities
- Import of petroleum products from Belneftekhim-linked entities
- New investment in Belarus by U.S. persons (under EO 14038)
- Export of certain goods and technologies to Belarus
- Processing USD payments through U.S. correspondent banks for SDN-linked parties
How Our Lawyers Can Help
If your assets have been blocked due to Belarus-related OFAC sanctions, or if you appear on the SDN list in connection with a Belarusian entity, our OFAC sanctions lawyers can assist with SDN list removal, OFAC licensing, and EU sanctions compliance. Contact us at [email protected] or WhatsApp/Telegram: +357 96 447475.
Belarus Sanctions FAQ
Is Belarus comprehensively sanctioned by OFAC?
No. Belarus faces targeted OFAC sanctions under EO 13405 and EO 14038, targeting specific individuals, entities, and sectors. Unlike Iran or Cuba, transactions with non-designated Belarusian parties are generally permitted.
What is Belneftekhim and why is it sanctioned?
Belneftekhim is Belarus’s state petrochemical company and one of the primary OFAC-designated entities. OFAC designated it for supporting the Lukashenko government. All subsidiaries and affiliates are also covered by the designation.
Can I do business with Belarus in USD?
It depends. Payments in USD through U.S. correspondent banks are subject to OFAC screening. If your Belarusian counterparty is on the SDN list, any USD transaction — even through a non-U.S. bank — may be blocked by the correspondent bank.
Are EU Belarus sanctions different from U.S. OFAC sanctions?
Yes, significantly. EU sanctions on Belarus include sector-specific restrictions on potash exports, oil products, financial services, and transport — much broader than U.S. targeted designations. Businesses must comply with both regimes.
What should I do if my Belarus payment was blocked?
Contact our OFAC lawyers immediately. We can determine whether the blocking was correct, apply for an OFAC specific license for release, or pursue SDN removal if your counterparty was incorrectly designated.
How do I screen for Belarus sanctions risk?
Screen all Belarusian counterparties against the OFAC SDN list and EU consolidated sanctions list. For high-value transactions, enhanced due diligence including beneficial ownership verification is recommended.