New Counter-Sanctions Rules in Belarus: What Is Important to Know

In Belarus, the rules relating to counter-sanctions have been updated. The amendments were introduced by Law No. 109-Z of 08 December 2025 to Law No. 280-Z “On the Application of Special Restrictive Measures”. This law previously served as the basis on which the Council of Ministers imposed restrictions on the payment of dividends to persons from “unfriendly” countries.

Key amendments

Additional powers granted to state bodies

State bodies may now request information from any organisations—both Belarusian and foreign—that fall within the scope of Belarusian law (for example, those having branches in Belarus).

Such requests may concern:

• the implementation of special restrictive measures;
• the company’s financial and economic activities in the context of compliance with the requirements of special restrictive measures.

The scope of persons to whom restrictions may apply has been clarified

Previously, measures were introduced in respect of entire states.
Now, restrictions may also be applied to specific foreign persons, and not only to countries as a whole.

Temporary external administration of companies: new rules

Law No. 108-Z of 08 December 2025 introduced amendments to Law No. 239-Z “On Issues of Transfer under Temporary External Administration”, which governs cases in which a company may be transferred under temporary external administration.

What is new:

Temporary administration in the event of a company’s liquidation

Temporary external administration may now be introduced, inter alia, in respect of:

• a company that is in the process of liquidation;
• but only where the decision to liquidate was adopted by the company itself (through the authorised body—under the charter/articles of association or by law).

Important:
Temporary external administration, as before, does not apply where liquidation has been commenced:

• by decision of the registering authority;
• by decision of an economic court.

Additional rights of the temporary external administrator in relation to companies undergoing liquidation

If the decision to liquidate was adopted by the company itself, the temporary administrator may revoke the decision on liquidation.

Where such liquidation decision is revoked, the administrator must, within 10 working days, notify:

• creditors;
• the registering authority;
• the regional executive committee (oblast executive committee) or the Minsk City Executive Committee (which adopted the decision on temporary administration).

The duration of the mechanism has been extended

The possibility of introducing temporary external administration will now remain in force until 31 December 2028 (previously, the deadline was 31 December 2025).

Authors: Nikita Tolkanitsa, Matsvei Shastsiarniou.