A foreign engineering company is finalising a multi-year supply contract with a Belarusian industrial buyer. Procurement is happy. Commercial terms are clean. The in-house lawyer in Vienna, who picked up the file on a Friday afternoon, opens what she thinks will be a forty-five-minute job — run the counterparty against a sanctions list, send the file back to procurement, log the time.
Three hours later she’s still at her desk.
There’s the OFAC SDN list. There’s a separate EU consolidated list. There’s a UK list that doesn’t quite line up with either. Four sectoral regulations have to be read. Annex XXX of Council Regulation 765/2006 mentions something called Common High Priority Items, and the contract sitting on her screen has a quiet absence — no “no re-export to Belarus” clause. On top of all that, there’s a Belarusian Council of Ministers resolution that suspends enforcement of certain decisions in favour of foreign creditors from a list of “unfriendly” states, and Austria is on that list. Some of these documents were updated last month. None of them talks to any of the others.
That scenario plays out in our office, in some versions, more weeks than not. So here’s the long-form answer to the question foreign in-house teams ask us most often in 2026: when a transaction touches Belarus, what does an actually adequate sanctions and due diligence check look like — and where do companies most often get it wrong?
We’ll go through the four-jurisdiction structure of the problem, the screening and sectoral layers, the recent shifts that have moved the answer in the past two months, and a working checklist you can run against a specific transaction. None of this is legal advice for any particular deal. But it’s the framework we use ourselves, and it’ll save you a fair amount of the time that lawyers in Vienna are currently losing.
Foreign companies tend to think of sanctions on Belarus as a single regime. It isn’t. There are at least four distinct legal regimes that a transaction touching Belarus can trigger, and they don’t share definitions, lists, or thresholds. Worse, in 2026 they’re moving in different directions for the first time since 2022.
Here’s the structure in one table.
| Regime | Key legal sources | Listings (May 2026) | Recent direction |
|---|---|---|---|
| EU | Council Regulation (EC) 765/2006, Council Decision 2012/642/CFSP, as amended through the 20th sanctions package (April 2026) | 310 individuals, 46 entities under the main regime; sectoral measures across finance, energy, transport, defence, dual-use, services, and crypto | Tightening. 20th package adopted 23 April 2026; first activation of the EU’s anti-circumvention tool against a third country (Kyrgyzstan) |
| UK | Republic of Belarus (Sanctions) (EU Exit) Regulations 2019; Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 | Largely aligned with EU plus UK-specific additions | New direction. Notification-based end-user licensing in force 13 May 2026 across all 36 UK sanctions regimes |
| US | Executive Orders 13405 and 14038; Belarus Sanctions Regulations (31 CFR Part 548); OFAC general licences | OFAC SDN list, modified in March 2026 | Selective easing. Three potash companies delisted; General License 14 (26 March 2026) authorises certain Belinvestbank transactions; Belarus Ministry of Finance prohibition removed |
| Belarus (countermeasures) | Council of Ministers resolutions on the list of “unfriendly” states; suspension of enforcement in force since 10 April 2022 | Includes EU member states, UK, US, Canada, Switzerland, Australia, Norway, Iceland, Albania, North Macedonia, Montenegro, New Zealand, Liechtenstein | Stable. Updated periodically. Affects enforcement, not recognition |
What the table doesn’t show, but every compliance team needs to absorb, is this: the same transaction can be permissible under the EU regime, prohibited under the US regime (or the other way round, post-March 2026), and on top of all that, subject to Belarusian-side restrictions on the enforcement of any judgment or award you might later need against the Belarusian counterparty. A compliance review that addresses only one of these four regimes is structurally inadequate. We’ve seen reviews from quite reputable European firms miss the Belarusian counter-regime entirely, then have to redo the analysis when the transaction reached the credit committee.
We’ve covered the Belarusian-side enforcement piece in detail in our arbitration vs courts article — that’s the place to read up on what the post-April 2022 regime actually does at the bailiff stage. The rest of this article works through the other three layers.
Every sanctions check starts here, and many of them stop here too. That’s the first mistake.
List screening means running your counterparty — and ideally everyone in their ownership chain — against the official designated-persons lists maintained by each relevant jurisdiction. The minimum set for any Belarus-touching transaction is:
OFAC SDN list for any transaction that touches the US financial system, US-origin goods, or US persons. The full list is on OFAC’s Belarus sanctions page along with the relevant general licences and FAQs.
EU Consolidated List of persons, groups and entities subject to EU financial sanctions. The Council’s Belarus sanctions hub gives you the official entry point, and the EU Sanctions Map is the most usable interface for cross-referencing the various regimes.
UK OFSI Consolidated List for any transaction touching UK persons, UK financial system, or UK-origin goods. Updated frequently and available through the UK government website.
Other regional lists matter where they touch your group footprint — Canadian, Swiss, Australian, Norwegian, and so on. If your corporate group has any operating presence in those jurisdictions, those lists belong in your standard screening set.
Here’s where companies most often go wrong. Three patterns we see repeatedly:
First, screening only the immediate counterparty. The OFAC 50% rule pulls in any entity that is fifty percent or more owned, directly or indirectly, by one or more designated persons. The EU and UK go further, applying broader “ownership and control” tests that can reach entities below the fifty percent threshold where control is exercised in practice — through, say, a management agreement, a shareholders’ agreement, or a chain of nominees. If your screening only checked the legal name on the contract, you haven’t finished.
Second, treating screening as a one-off. Lists update constantly. A counterparty that was clean three weeks ago may have been designated since. We re-screen at contract signing, at each major payment, and on receipt of any list update from the regimes that apply to our client. For long-running relationships, an annual refresh is the absolute floor — and for medium-risk counterparties, quarterly is closer to defensible.
Third, treating the counterparty’s self-certification as the answer. Counterparty representations and warranties absolutely belong in the contract — we’ll come back to that — but a representation that “we are not a sanctioned person” is a contractual allocation of risk, not a substitute for your own diligence. Regulators have made clear, repeatedly, that they expect institutions to do their own work. Reliance on counterparty self-certification looks like willful blindness when something goes wrong.
And one more thing that’s tightened recently. Council Regulation (EU) 2025/390 introduces a “best efforts” obligation on EU companies to ensure that their non-EU subsidiaries (those they own at fifty percent or more, or otherwise control) do not engage in conduct that undermines the EU sanctions regime, including the Belarus regime. Practically, that means screening obligations now extend up the corporate group. If your Singapore subsidiary wants to do business with a Belarusian counterparty, your EU parent has its own “best efforts” exposure to manage. Most foreign companies are still catching up to this one.
List screening tells you whether you can deal with this person. The sectoral rules tell you whether you can deal in this transaction. They operate independently — and you can pass the first check while flunking the second.
The categories that matter most for foreign companies trading with Belarusian counterparties:
Banking and finance. Restrictions on transactions with the Central Bank of Belarus, with four named Belarusian banks, with EU-based financial messaging services to Belarusian banks, and with crypto-asset service providers established in Belarus (the last one is brand new — added in the EU’s 20th package, effective 24 May 2026). The US position on Belinvestbank specifically changed in March 2026, which means a transaction routed through Belinvestbank may now be permissible for US persons under General License 14 while remaining problematic under EU rules. Worth knowing exactly which entity is on which list before you wire anything.
Dual-use goods and military goods. Annex Va of Regulation 765/2006 covers dual-use items. The EU’s Common Military List captures military goods. Aviation, space, and defence technology has its own ban. Transit of these goods through Belarus is also prohibited — meaning a shipment from your German supplier to your Kazakh customer that crosses Belarus by road is in scope, even if neither end-party is Belarusian. Classification of goods sits with the exporter, and misclassification is one of the most common compliance failures we see. “We didn’t realise it was dual-use” is not a defence.
Common High Priority Items (CHPI). Annex XXX of Regulation 765 (and Annex XXXI, added in 2025) lists items that are particularly susceptible to diversion to the Russian or Belarusian defence sector — switch devices, certain piston-engine generating sets, integrated circuits, certain machine tools, and others. EU operators dealing in CHPI items have to implement a compliance programme under Article 12gb, conduct documented risk assessments for diversion to Belarus, and apply equivalent controls to their non-EU subsidiaries. The bar here is materially higher than ordinary screening.
Energy and mining. No new investment, no new loans, no new joint ventures with entities operating in the Belarusian energy or mining sectors. Existing positions are generally permitted to run, but expansion is not.
Imports from Belarus. Bans on potash (with the US easing carve-out from March 2026), wood and cement products, iron and steel, gold, diamonds, helium, coal, mineral products including crude oil. Plus anything on the Common Military List originating in or exported from Belarus. Each ban has its own set of carve-outs and transitional periods worth checking in detail.
Professional services. EU restrictions on the provision to the Belarusian government and certain state entities of accounting, audit, business consulting, public relations, architectural, engineering, IT consulting and (since the 20th package) construction services. Limited carve-outs for legal advisory work, but the carve-outs are narrower than they look at first reading. Cybersecurity services to the Belarusian government, and tourism services in Belarus, were also added in April 2026.
Crypto and digital assets. The 20th package shifted the EU approach from listing individual platforms to a blanket prohibition on EU persons engaging with any crypto-asset service provider established in Belarus, plus a transaction ban on the Belarusian digital ruble. Effective 24 May 2026. This is a meaningful change in approach — it means jurisdictional screening, not just name screening, for any crypto-related activity.
Each of these areas has carve-outs, derogations, transitional periods, and licensing routes. The point of this article isn’t to enumerate every one. It’s structural: a complete check requires going through each category and asking, in each case, whether the contemplated transaction falls inside or outside. “We screened them and they’re clean” doesn’t answer the sectoral question. It answers a different question.
Since June 2024, EU exporters of certain goods have been required to include a “no re-export to Belarus” clause in their contracts with non-EU buyers. The clause isn’t a recital. It’s a substantive contractual obligation, and tribunals in EU member states have started treating its omission as a sanctions-compliance failure in itself.
What the clause needs to do, at a minimum:
Prohibit re-export of the goods to Belarus or for use in Belarus. Provide adequate remedies for breach — termination, substantial penalties, the works. Apply to the specified categories of goods (dual-use items, items on the CHPI list, advanced technology goods, firearms, aviation and space goods). Push the obligation down through the buyer’s own resale chain where applicable.
There are equivalent or comparable obligations under UK and US frameworks. They aren’t identical. A clause that satisfies the EU regulation may be insufficient under UK or US export controls — which means a single supply contract serving multiple corporate group jurisdictions often needs layered compliance language, not a single off-the-shelf paragraph.
Beyond the no-re-export clause, the contractual layer for any Belarus-touching transaction should include sanctions representations and warranties from the counterparty (they aren’t a sanctioned person; they won’t knowingly become one; they’ll notify on any change), a termination right for sanctions breach, and a governing-law and dispute-resolution clause that anticipates the post-2022 Belarusian enforcement environment. The dispute-resolution piece is its own conversation, treated in our arbitration vs courts piece.
We draft these contractual packages regularly through our contract law and commercial transactions practice, usually as part of a broader entry-or-continuing-trade compliance review.
If you read one section of this article, read this one. Most generic sanctions content sitting on the open web hasn’t absorbed the spring 2026 movements yet, and the picture has shifted enough that pre-March 2026 frameworks now produce wrong answers in real situations.
EU 20th sanctions package, adopted 23 April 2026. The Belarus-relevant elements: the regime extended through 28 February 2027; first-ever designation of a Chinese state-owned entity under the Belarus regime (signalling that anti-circumvention enforcement will reach third-country actors directly); blanket ban on EU persons dealing with crypto-asset service providers established in Belarus; ban on transactions involving the Belarusian digital ruble; restrictions on cybersecurity services to the Belarusian government and on tourism services in Belarus; expansion of items subject to the prohibition on transit via Belarus; first activation of the EU’s anti-circumvention tool against Kyrgyzstan, with related implications for re-export corridors.
US easing, March 2026. OFAC removed sanctions on three Belarusian potash companies — Belaruskali, Belarusian Potash Company, and Agrorozkvit. General License 14, issued 26 March 2026, authorises certain transactions involving Belinvestbank and certain related entities. The prohibition on transacting with the Belarus Ministry of Finance was removed. The easing followed the release of approximately 250 detainees by Belarus.
The thing to absorb here is that, for the first time since 2022, the US position on certain Belarus transactions diverges meaningfully from the EU and UK positions. A US person may now be able to do business with Belaruskali that an EU person cannot. A transaction routed through Belinvestbank may now clear OFAC under GL 14 while still failing on the EU side. This sort of regime divergence wasn’t a real factor for most of 2022 to 2025; it is now. Compliance frameworks that assumed parallel regimes need updating.
Important caveat: easing on specific entities does not lift the broader regime. Belarus remains comprehensively sanctioned by the US. The general licences are narrow and conditional. Read the actual licence text, not the press summary.
UK Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026, in force 13 May 2026. These introduce a notification-based end-user licensing requirement across all 36 UK sanctions regimes, including Belarus and Russia. Where the UK government identifies diversion risk to a sanctioned destination, the exporter is formally notified by the Department for Business and Trade. Once notified, the exporter must obtain a licence before exporting the relevant goods or technology. Non-compliance opens the door to detention of goods, financial penalties, or criminal investigation.
Read across the three movements together and the structural picture is this: the EU is tightening, the US is selectively easing, the UK is introducing new end-user controls. For multi-jurisdictional companies, that means a transaction’s compliance status now depends explicitly on which entity in the corporate group is conducting it. “We checked the rules” is no longer enough. The right question is: “which rules apply to which entity, doing what, on which date?”
We’ll keep this brief because we’ve covered it elsewhere. But it has to sit in any due diligence framework for a Belarus-touching transaction, because the legal exposure runs in both directions.
Since 10 April 2022, Belarus has suspended the enforcement of decisions in favour of residents of states designated as committing “unfriendly actions.” The list is set by the Council of Ministers and updated periodically; the current version is published on pravo.by. It covers EU member states, the UK, US, Canada, Switzerland, Australia, and several others.
What this means operationally: if you obtain a money judgment or arbitral award against a Belarusian counterparty, and you’re a resident of an unfriendly state, the actual collection step against assets in Belarus may be suspended. Recognition of the decision is generally still available; what’s suspended is enforcement. This affects forum-choice decisions in the underlying contract — meaning the value of any contractual remedy you draft today depends partly on whether this regime continues or not. It also affects credit risk: a counterparty who knows enforcement is suspended has less reason to perform voluntarily.
The detail is on our practice page for recognition and enforcement of foreign court judgments, which covers both court judgments and arbitral awards in this context.
Here’s the workflow we use ourselves when scoping a Belarus-touching transaction for a foreign client. It’s not a one-day exercise on a complex deal. But on a routine commercial counterparty, an experienced compliance lawyer can run the full sequence in roughly a working day, plus list-screening time.
Stage one — counterparty identification. Full legal name in Cyrillic and transliteration variants (a surprising number of false positives and false negatives come from name-matching alone). Registration in the Unified State Register of Legal Entities (EGR). Beneficial ownership chain mapped to ultimate beneficial owners. Director, supervisory board, and senior management identified. Any related parties or affiliates the counterparty habitually acts through.
Stage two — sanctions list screening. OFAC SDN, EU Consolidated, UK OFSI as the minimum. Other regional lists where your group footprint requires it. Apply the OFAC 50% rule and the EU/UK ownership-and-control tests across the full ownership chain, not just the immediate counterparty. Document the screening clearly enough that a regulator could reproduce it.
Stage three — sectoral and goods classification. Classify the goods or services involved by HS code, dual-use status, CHPI status. Identify which sectoral regimes apply — financial, energy, transport, professional services, crypto, dual-use. Check transit prohibitions if any leg of the transaction passes through Belarus. If the answer to any of these is “maybe,” treat that as a “yes” and dig further.
Stage four — contractual compliance build. Insert the “no re-export to Belarus” clause where required (and tailor it to the goods category). Add sanctions representations and warranties. Add a termination right for sanctions breach. Build the governing-law and dispute-resolution clause anticipating the Belarusian enforcement environment. Cross-check that what you’ve drafted holds up under all the jurisdictions your corporate group touches, not just the one where the contract is being signed.
Stage five — payment-channel verification. This is the stage most often skipped, and the one most likely to torpedo an otherwise compliant transaction. Confirm with your bank — in writing — that they will process incoming or outgoing transfers from or to a Belarusian counterparty. Some Western banks decline Belarusian correspondent transactions categorically, regardless of whether the underlying transaction is sanctioned. If your bank can’t process, the workarounds (opening a dedicated Belarusian-bank account, assigning the claim to a resident third party) need to be put in place before you sign, not after. Our debt recovery piece walks through the practical mechanics of this in detail.
Stage six — ongoing monitoring. Subscribe to alerts from OFAC, the EU Council, UK OFSI, and pravo.by. Schedule periodic refreshes — annually for low-risk counterparties, quarterly for medium-risk, and continuously where you’re carrying real exposure. Adverse-media monitoring on counterparty UBOs picks up red flags that don’t make it onto official lists for months.
Stage seven — documentation. Maintain a written sanctions compliance policy. Keep dated screening records, classification analyses, contractual review notes, and approval decisions for every transaction. Documentation is what evidences “adequate due diligence” when questions come up later — and the absence of a paper trail is itself a compliance failure in the eyes of every regulator we’ve dealt with. If it isn’t written down and dated, it didn’t happen.
Some patterns that, in our experience, warrant slowing down and digging deeper before proceeding:
A counterparty that resists ownership disclosure, or routes ownership through known secrecy jurisdictions with no commercial rationale. A payment route that runs through a third-country intermediary in Kyrgyzstan, the UAE, or certain Türkiye-based hubs without a clear commercial reason — these corridors are explicitly named in EU anti-circumvention guidance, and the EU’s first activation of its anti-circumvention tool in April 2026 was against Kyrgyzstan precisely for this reason. A goods order that doesn’t match the counterparty’s commercial profile (a small distributor placing a quantity of CHPI items normally bought by industrial end-users). Pressure to ship before classification or end-use checks are complete. Counterparty insistence on payment in cryptocurrency or via Russian or Belarusian-domiciled crypto service providers — now categorically prohibited under the EU’s 20th package. Shipping documentation that obscures the ultimate destination, or end-use certificates that read as boilerplate. Recent changes in the counterparty’s corporate structure that coincide with sanctions designations of related entities.
None of these on its own is conclusive. Each of them, by itself, has innocent explanations. But adequate diligence means investigating the explanation rather than accepting it on its face. “The counterparty assured us” is, again, not a defence.
Where a red flag holds up under enhanced diligence, the decision tree is straightforward enough: refuse the transaction, restructure the transaction so the flag goes away, or apply for a specific licence from the relevant authority. Our government relations practice handles licence and derogation applications on the Belarusian side; for OFAC, EU, or UK licence applications, you’ll usually want counsel admitted in those jurisdictions to lead.
No. The EU sanctions regime is targeted, not comprehensive. EU companies can still trade with Belarusian counterparties in many sectors, subject to list screening, sectoral checks, and the contractual obligations described above. What the regime prohibits is dealing with designated persons (and entities they own or control), trading in restricted goods or services, and transacting through restricted channels. Each transaction needs to be analysed; categorical statements either way are wrong.
Definitely not. The easing is narrow and conditional. Three potash companies were delisted, and General License 14 authorises a defined set of transactions involving Belinvestbank. The broader US sanctions regime against Belarus — including the prohibition on dealing with most designated Belarusian banks and individuals — remains in force. Read the actual licence text before you assume anything. “General licence” in OFAC parlance does not mean “everything is now fine.”
The OFAC 50% rule is a bright line: an entity that’s fifty percent or more owned, directly or indirectly, by one or more blocked persons is itself blocked, regardless of whether it appears on the SDN list. The EU and UK use a broader test that looks at both ownership and control. An entity below the fifty percent ownership threshold can still be “controlled” by a designated person through, say, a management agreement, voting rights, or a chain of nominee arrangements. In edge cases — ownership at exactly fifty percent, or fragmented ownership across designated and non-designated holders — the EU and UK tests can capture entities that the OFAC rule does not, and the other way round. The European Commission’s consolidated FAQ on Russia and Belarus sanctions is the working reference for these tests on the EU side and is updated as new guidance comes out.
Directly, no — the EU sanctions regime applies to EU persons and to conduct with an EU nexus. Indirectly, yes — Council Regulation (EU) 2025/390 imposes a “best efforts” obligation on the EU parent to ensure that you (as a 50%+ owned or controlled non-EU subsidiary) don’t engage in conduct that undermines the EU sanctions regime. In practice this means EU parents are now requiring their non-EU subsidiaries to comply with EU sanctions as a matter of group policy, even where local law doesn’t require it. If you’re in this position and you haven’t had the conversation with your EU parent’s compliance team, have it now.
No. A counterparty’s sanctions representation belongs in your contract — it allocates risk and gives you a contractual remedy if the representation turns out to be false. But it doesn’t replace your own diligence obligation. Regulators have been consistent on this: institutions are expected to do their own work. Reliance on counterparty self-certification, where it turns out the counterparty was in fact sanctioned, is treated as a compliance failure of the institution, not just of the counterparty.
Stop. Pause any further performance, payments, or shipments. Do not return funds you’ve already received without taking advice — depending on the regime, returning blocked funds can itself be a violation. Notify your compliance function and your external counsel immediately. Depending on jurisdiction, you may have a reporting obligation to OFSI, OFAC, or the relevant national sanctions authority. The instinct to “unwind quietly” is almost always the wrong move; the regulators care more about disclosure than about the underlying breach in many cases.
Often yes — every major sanctions regime has a licensing or derogation route. The EU has derogations built into specific articles of Regulation 765/2006; the UK has general and specific licences via OFSI; the US has specific licences via OFAC. Belarusian-side derogations exist for certain enforcement applications. The application processes are formal and time-consuming, and outcomes vary. Build licence applications into your transaction timeline early, not as a last-minute fix.
Annually as the absolute floor for low-risk counterparties. Quarterly for medium-risk. Continuously (with automated screening tools) for any counterparty carrying real exposure or operating in a high-risk sector. And always re-screen at the moment of any major payment or contract renewal, regardless of where you are in the periodic cycle. Lists move faster than calendar quarters do.
No. Companies from states that aren’t on the Council of Ministers list — most CIS countries, China, Türkiye, the GCC, India, large parts of Asia, Africa, and Latin America — are not affected by the enforcement-suspension regime. For those companies, the analysis runs without that thumb on the scale. But all of the EU, UK, and US sanctions analysis above still applies if your group has any presence or activity in those jurisdictions.
They scale with the regime and the conduct. Civil penalties under OFAC, EU member-state, and UK frameworks can reach tens of millions for serious breaches. Criminal liability is on the table for individuals in cases of willful non-compliance, particularly under UK and US frameworks. Reputational consequences — being named in an enforcement action, or being de-banked by your relationship bank — often outrun the financial penalties in real terms. And in our own experience advising on the unwinding of compliance failures: the cost of fixing a sanctions breach after the fact is consistently a multiple of what proper diligence would have cost up front.
In 2026, “Belarus sanctions compliance” isn’t a single check against a single list. It’s a four-jurisdiction analysis — EU, UK, US, Belarusian counter-regime — conducted through a structured workflow, repeated on a defined cadence, and documented against the day a regulator or your auditor asks the question.
The structural risk for foreign companies in 2026 isn’t deliberate non-compliance. It’s incomplete compliance: an analysis that addressed three of the four regimes, that screened the counterparty but not the ownership chain, that classified the goods correctly but missed the transit prohibition, that included a sanctions representation but not a no-re-export clause. The EU’s first activation of its anti-circumvention tool in April 2026, and the UK’s introduction of notification-based end-user licensing the following month, both signal the same thing: “we ran our standard check” is no longer an adequate defence where the standard check missed a layer.
Our team scopes and runs sanctions compliance reviews for foreign clients across all three of those scenarios — pre-transaction diligence, ongoing-relationship monitoring, and post-incident response. We coordinate with EU, UK, and US-admitted counsel where required, and we handle the Belarusian-side analysis (counter-regime exposure, licence applications, contractual structuring) in-house. If you’re evaluating a new transaction, reviewing an existing exposure, or trying to put a defensible compliance framework in place for ongoing trade with Belarus, get in touch. We’ll tell you which layers your current process is missing, what the practical fix looks like, and where the specific risks sit on your particular fact pattern. Our legal opinions and due diligence practice is built around this kind of work.And if you’re instead at the other end — winding down a Belarus presence rather than entering into one — our companion piece on the exit of foreign businesses from Belarus is the better starting point.
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