EU and US Sanctions on Belarus Diverge Amid Recent US Easing Measures

Sanctions against Belarus have evolved significantly since their inception. The European Union first imposed sanctions in 2004 targeting officials linked to the disappearance of opposition figures, while the United States introduced its initial measures in 2006 against individuals undermining democratic processes. Both jurisdictions have adjusted their sanctions regimes over time, tightening or easing restrictions in response to political developments between 2008 and 2021.

The geopolitical landscape shifted markedly in 2022 when Belarus provided logistical and territorial support for Russia’s invasion of Ukraine, including permitting Russian troops to operate from Belarusian territory. This prompted substantial expansions of sanctions by both the EU and the US. The EU adopted sanctions packages largely mirroring those targeting Russia, whereas the US implemented broader measures against Belarus.

In a notable departure, the US Treasury’s Office of Foreign Assets Control (OFAC) began easing sanctions under specific conditions tied to the release of political prisoners. In September 2025, OFAC issued General License (GL) 11 authorizing all transactions involving Belavia, Belarus’s national airline, following the release of 52 political prisoners. Subsequently, Belavia was removed from the Specially Designated Nationals (SDN) List in November 2025, accompanied by GL 12 concerning President Lukashenko’s aircraft.

Further easing occurred in December 2025 with GL 13 authorizing transactions with Belaruskali, Belarusian Potash Company (BPC), and Agrorozkvit. On 26 March 2026, OFAC issued a comprehensive package that included delisting these three potash entities from the SDN List, rescinding Directive 1 under Executive Order 14038 (which restricted sovereign debt dealings), and issuing GL 14 authorizing transactions with Belinvestbank. Each phase of easing followed Belarusian prisoner releases, the most recent involving approximately 250 prisoners in March 2026. The US aims to secure the release of an additional 900 prisoners, potentially leading to removal of about 80% of US sanctions on Belarus.

In contrast, the European Union maintains a comprehensive and consistent sanctions regime against Belarus. Entities such as Belavia and the potash companies remain subject to asset freeze restrictions under EU law. This divergence raises critical questions about the treatment of ongoing business operations and new investments in Belarus under EU sanctions law, despite US delistings.

Regarding the potash sector, while OFAC’s December 2025 GL 13 authorized transactions with Belaruskali, BPC, and Agrorozkvit, and these entities were removed from the SDN List in March 2026, the EU’s position remains unchanged. EU law continues to prohibit the import, purchase, or transfer of Belarusian potash within the EU. The three entities remain subject to EU asset freezes, meaning EU persons cannot provide funds or economic resources to them regardless of US delisting. Consequently, companies relying on EU-based banks, insurers, or shipping agents remain barred from transacting with these Belarusian potash firms. Third-country buyers also face reputational risks sourcing potash through EU channels.

For Belarus’s national airline Belavia, the US easing began with OFAC’s GL 11 in September 2025 authorizing all transactions, alongside the US Bureau of Industry and Security restoring access to Boeing spare parts and maintenance services. However, the EU continues to prohibit all Belarusian carriers from entering or overflying EU airspace, a measure imposed in June 2021 following the forced diversion of Ryanair flight FR4978 and the arrest of journalist Raman Pratasevich.

Belavia has been designated under EU asset-freeze sanctions since December 2021, preventing European lessors, insurers, and maintenance, repair, and overhaul (MRO) providers from conducting business with the airline. Given that principal aviation insurance and reinsurance markets are located in the EU and UK, these restrictions significantly impact Belavia’s operations. The airline’s fleet has shrunk from approximately 30 to 19 aircraft, and fleet renewal through Western channels remains unavailable. The EU airspace ban removes Belavia’s most commercially significant pre-sanctions routes, forcing circuitous routing for westbound or southbound flights.

In the banking sector, OFAC’s GL 14 issued on 26 March 2026 authorized transactions with Belinvestbank, Belinvest-Engineering, CJSC Belbizneslizing, and their subsidiaries indefinitely. Concurrently, OFAC rescinded Directive 1 under EO 14038, lifting prohibitions on dealings in Belarusian sovereign debt with maturity exceeding 90 days issued by the Ministry of Finance and the Development Bank of the Republic of Belarus.

The EU’s stance diverges sharply. Since March 2022, the EU has prohibited SWIFT services to several Belarusian banks, including Belagroprombank, Bank Dabrabyt, the Development Bank, and Belinvestbank. By July 2025, these restrictions evolved into a prohibition on any transactions with these credit institutions or Belarusian entities more than 50% owned by them. In October 2025, the EU added additional Belarusian banks to its sanctions list under the Russia sanctions regime, resulting in nine Belarusian banks being subject to a total transaction ban. The EU also continues to prohibit dealings in Belarusian sovereign debt with maturity exceeding 90 days issued after 29 June 2021.

This divergence creates practical challenges. Dollar-denominated transactions authorized by OFAC cannot clear through Euroclear, Clearstream, or any EU-regulated correspondent bank. Multinational banks with EU branches face conflicting obligations: US law permits these transactions, but EU law prohibits them. Most global banks default to the more restrictive EU regime. European clearing and settlement systems remain unavailable for newly issued Belarusian sovereign instruments, and investors with EU-regulated custodians or fund structures cannot hold such instruments regardless of OFAC’s position.

More broadly, the US has not imposed a blanket services ban on Belarus comparable to the EU’s regime, nor has it enacted comprehensive trade bans on Belarusian commodities. Since June 2024, the EU has progressively aligned its Belarus sanctions with its Russia sanctions regime, significantly broadening import and export restrictions.

On imports, the EU bans Belarusian crude oil, iron and steel, gold, diamonds, helium, coal, mineral products, cement, rubber, wood, and tobacco, extending these prohibitions to mirror the expanding list of Russian-origin goods barred from EU entry. On exports, the EU imposes comprehensive bans on dual-use and advanced technology items, goods contributing to Belarusian industrial capacity, maritime navigation equipment, oil refining and LNG technology, aviation goods, luxury goods, and related technical and financial assistance.

The EU also enforces a comprehensive ban on providing certain business services to the Belarusian government, including accounting, auditing, consulting, public relations, architectural, engineering, legal advisory, IT, advertising, and market research services, as well as specified software for enterprise management and industrial manufacture. Transport restrictions include prohibiting Belarusian road transport operators from operating within the EU, banning Belarusian ships from EU ports, and prohibiting transit of dual-use goods, military items, and other sensitive products via Belarus.

Additionally, the EU mandates “no-Belarus” clauses in contracts prohibiting the re-export of certain controlled goods to Belarus and imposes due diligence requirements on EU suppliers of high-priority items. This alignment with Russia sanctions means an expanding range of goods cannot be imported from or exported to Belarus by any EU person or from EU territory, even where no comparable US restriction exists.

From a sanctions-compliance perspective, the Eurasian Customs Union, established in 2010 between Russia, Belarus, Kazakhstan, Armenia, and Kyrgyzstan, has substantially reduced customs border checks between Russia and Belarus. This increases the practical risk that goods, technology, or funds lawfully entering Belarus—potentially under non-EU sanctions relief—may be diverted onward into Russia, potentially undermining the effectiveness of EU restrictive measures targeting Russia.