New EU Sanctions Against Belarus: Banking Sector and Investment Disputes
On 18 July 2025, a new package of restrictive measures by the European Union (EU) against Belarus came into force. The new restrictions were introduced by EU Regulation No. 2025/1472 and EU Regulation No. 2025/1469.
As in previous sanctions packages, the new EU measures include an expansion of personal blocking measures against Belarusian legal entities as well as new sectoral sanctions. Special attention in this package is given to the recognition and enforcement within the EU of judicial and arbitral decisions issued in investment disputes against EU member states.
In this material, REVERA lawyers provide a detailed analysis of the newly introduced restrictions.
Blocking Sanctions
As part of the new package, the EU has added 8 Belarusian legal entities to the blocking sanctions list.
Inclusion in the EU’s blocking sanctions means freezing of assets and a total ban on conducting business within the EU jurisdiction. The restrictions prohibit any person in the EU or any EU resident legal/natural person, regardless of location, from:
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carrying out transactions with assets, wherever located, that are owned, held, or controlled by sanctioned entities or persons acting on their behalf;
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providing any financial or related services in connection with sanctioned entities;
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supplying any goods, wherever located, to sanctioned entities or persons acting on their behalf.
Banking Sector
The EU has imposed a complete ban (Article 1zb of Regulation No. 765/2006) on any financial transactions with four Belarusian banks – Belagroprombank, Bank Dabrabyt, Development Bank of the Republic of Belarus, and Belinvestbank, as well as their subsidiaries in which these banks hold directly or indirectly a 50% shareholding.
However, the ban does not apply to the following categories of transactions:
- transactions necessary for the operation of EU diplomatic and consular missions, EU member states, or partner countries in Belarus, including delegations, embassies, and missions, as well as international organizations located in Belarus and enjoying immunity under international law;
- transactions carried out by EU citizens who are residents of Belarus and who were in such status before 24 February 2022.
Previously, the EU had already prohibited these banks from accessing specialized financial messaging services (SWIFT). Together with the full financial ban, this effectively blocks any payments involving EU residents and these banks.
Trade Restrictions
Imports into the EU of goods and technologies (Common Military List) originating from or exported from Belarus are prohibited. Similarly, the export of such goods and technologies for use by Belarusian entities or within Belarus is banned.
Other restricted items include chemical industry products, plastics, spare parts, and more.
End-Use Control
The EU has also amended provisions regarding the export control of goods and technologies that could contribute to Belarus’s military-technical development or its defense and security sector. In particular, Article 1f (paragraph 1aa) of the Regulation introduces an end-use control mechanism, even if the export of goods/technologies is not directly to Belarus.
Under this provision, the export of goods and technologies listed in Annex Va requires prior authorization from EU member states if the competent authority informs the exporter that such items may be wholly or partly intended for use in Belarus or by Belarusian legal/natural persons, even where the actual destination is a third country (e.g., Kazakhstan, Armenia, Turkey, etc.).
Investment Dispute Resolution
The new EU measures regarding sanctions-related investment disputes include:
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Obligations for EU member states not to recognize judicial and arbitral investment awards made outside the EU and instructions to actively oppose such disputes; and
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Mechanisms allowing EU member states to recover damages arising from such disputes.
Firstly, Article 8d (2a) of the updated Regulation provides that court judgments and arbitral awards rendered outside the EU in investment disputes against EU member states shall not be recognized or enforced within the EU if they are intended to satisfy claims related to restrictive (sanctions) measures.
This article also prohibits compliance with requests for legal assistance, as well as the enforcement of any fines, penalties, or other measures if they are based on such decisions issued in investment disputes outside EU jurisdiction that affect EU sanctions.
Secondly, the Regulation specifies situations where a claimant (investor), abusing their rights (“abusive dispute settlement proceedings”), initiates proceedings in a third jurisdiction. In such cases, the EU member state is entitled to recover any direct or indirect losses, including legal costs, incurred as a result of the dispute resolution proceedings initiated against it due to EU sanctions.
Additionally, Article 11f of the Regulation requires EU member states to actively oppose the recognition and enforcement of international investment arbitration awards rendered against them in connection with EU sanctions.
In upcoming materials, REVERA lawyers will provide a more detailed analysis of changes relating to the resolution of “sanctions-related investment disputes.” If you have any questions about the application of foreign restrictive measures, REVERA’s legal team is ready to assist.
According to the legislation of the Republic of Belarus, restrictive measures (sanctions) of third countries have no legal force on the territory of Belarus. This information may be useful when assessing foreign partners’ arguments regarding the presence or absence of restrictions on their side.
Author: Alexey Fedorovich
