Expansion of EU restrictive measures against the Republic of Belarus – 20th sanctions package
The European Union has adopted the 20th package of restrictive measures as part of its sanctions policy against the Republic of Belarus. The restrictions introduced under the latest package of EU sanctions cover both asset-freezing measures and sectoral, financial and trade restrictions.
The substantial expansion of the regulatory framework affects new sensitive areas, including transactions involving crypto-assets and digital currencies, restrictions on the provision of certain types of services, as well as enhanced control over cross-border financial flows and service models.
Particular attention is paid to the legal regulation of court proceedings, including attempts to enforce judgments in third, neutral states, as well as to mechanisms for protecting European persons and companies from related risks and losses.
Additional restrictions have been introduced affecting the provision of managed cybersecurity services, as well as certain types of service activities, including tourism services.
In this material, REVERA lawyers have analysed the substance of the restrictions introduced, their relationship with the previously applicable sanctions regime, as well as the potential consequences and risks of their practical implementation for business.
Personal asset-freezing restrictions
As part of the new package of restrictions, the EU has included three legal entities in the asset-freezing lists, including one resident of China, China Space Sanjiang Group.
The inclusion of persons or entities in EU asset-freezing sanctions means the freezing of their assets and a complete prohibition on doing business in that jurisdiction. The restrictions will include a prohibition on any person in the EU or any EU-resident legal or natural person, irrespective of their location, from:
- entering into transactions involving property, wherever it is located, which is owned, held or controlled by sanctioned persons, or by a person acting on their behalf;
- providing any financial or related services in respect of sanctioned persons;
- providing any goods, wherever they are located, to a sanctioned person or to a person acting on behalf of a sanctioned person.
Sectoral restrictions
From 25 May 2026, a prohibition is introduced on the provision of so-called managed security services, namely managed services in the field of information and cybersecurity. This refers to a broad range of services, from monitoring and protecting IT infrastructure to responding to cyber incidents and managing data security.
The prohibition applies to the provision of such services, whether directly or indirectly, for the benefit of:
- the Republic of Belarus and its public sector;
- as well as any persons and organisations acting on their behalf or at their direction.
In addition, the EU introduces a separate prohibition on the provision of services related to tourism activities in Belarus. Although the wording of the provision is rather broad, in practice it covers:
- services of travel agencies and tour operators, including services provided by travel agencies and tour operators in the field of passenger transport, as well as similar services; travel information services, advisory services and travel planning services; services related to the organisation of tours, accommodation, the transport of passengers and baggage; ticketing and ticket sales services;
- tourist guide services;
- advertising services related to the services referred to in points (a) and (b).
Trade restrictions
As part of the 20th package, the EU continues its course towards deepening trade sanctions, in particular:
- additional restrictions have been introduced on the export of dual-use goods and technologies;
- the list of goods contributing to the strengthening of Belarus’s industrial and technological capacity has been expanded;
- control has been strengthened over supplies of equipment used in the military and defence industry.
Restrictions in the crypto sector
The EU introduces a direct prohibition on any transactions involving certain crypto-assets and central bank digital currencies included in a special sanctions list, currently the Belarusian digital rouble.
The prohibition covers not only the execution of transactions, but also any assistance in the development of such instruments.
At the same time, an even more practice-oriented restriction is introduced: interaction with Belarus’s crypto sector is effectively blocked. European companies and natural persons are prohibited from directly or indirectly carrying out transactions with organisations that provide services related to crypto-assets or operate platforms for their exchange and transfer, if such organisations are registered in Belarus.
Thus, the restrictions apply to:
- crypto exchanges and exchange platforms;
- wallet providers;
- any intermediaries facilitating the circulation of crypto-assets.
At the same time, the legislator expressly refers to a prohibition on both direct and indirect interaction. As with other sanctions measures, limited exemptions are provided.
They primarily concern transactions necessary for the functioning of diplomatic and consular missions, as well as certain categories of natural persons, namely EU citizens who resided in Belarus before 24 February 2022.
These restrictions enter into force on 24 May 2026.
Dispute resolution
The 20th package of EU sanctions establishes the right of European companies and natural persons to claim compensation for losses if sanctions-related court proceedings are initiated against them outside the EU. This refers to cases where a counterparty, for example a resident of Belarus, brings proceedings before a court of a third country with claims relating to a contract whose performance has become impossible or restricted due to sanctions regulation.
If the European party has no real possibility of effectively protecting its interests in such jurisdiction, it obtains the right to apply to a court of an EU Member State and recover the losses incurred.
This concerns not only direct damage, but also indirect losses, including court and legal costs. Moreover, the range of potential defendants is not limited to the direct claimant in the foreign proceedings. Liability may also be imposed on persons and structures that control such claimant or benefit from the relevant claims.
It is important that the legislator at the same time draws the boundary of what is permissible: these mechanisms do not apply to judges or to lawyers participating in the relevant proceedings.
In addition, they are not directed against the European companies themselves in respect of which such judgments have been issued.
Enforcement of judgments
The newly introduced provisions of sanctions legislation are also aimed at a practice that has become fairly widespread in recent years: attempts to circumvent the sanctions regime through courts and enforcement mechanisms in third countries.
It is now expressly prohibited to enter into any transactions with persons and organisations seeking to obtain enforcement outside the EU of judgments based on claims arising from contracts affected by sanctions. The prohibition also applies to companies and structures that own such persons or control their activities.
It is important that the prohibition applies not only to the initiators of such actions themselves, but also to those who facilitate the enforcement process, for example by participating in the implementation of judicial acts or providing organisational support. At the same time, the restrictions do not apply to lawyers or representatives of the judiciary, which allows the basic guarantees of access to justice to be preserved.
Conclusion
As part of the 20th sanctions package, the European Union continues to strengthen sectoral and trade restrictions against Belarus, focusing on preventing circumvention of the sanctions regime and restricting access to critical technologies. An important point is the introduction of asset-freezing sanctions against a resident of a third state.
Restrictions on the export of dual-use goods and technologies have been expanded, including a broader list of components and technical solutions potentially applicable in both civilian and military fields. The list of goods regarded as contributing to the development of Belarus’s industrial and technological capacity has also been increased, including certain categories of equipment and products.
The package pays particular attention to new types of services and the digital economy. For the first time, direct restrictions on transactions involving crypto-assets and digital currencies have been included in the sanctions regime, together with prohibitions on interaction with Belarusian crypto services and exchange platforms. Regulation in the services sector is also being substantially expanded, including a prohibition on the provision of managed security services and certain tourism services.
A significant new development is also the strengthening of legal protection for European companies in cross-border disputes. The EU introduces additional mechanisms to counter attempts to enforce foreign court judgments and recover claims under sanctions-affected contracts in third countries, while also expanding the possibilities for compensation of losses and restricting interaction with persons involved in such processes.
Author: Aliaksei Fedarovich.
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