New EU Sanctions Against Belarus: Key Points to Consider

On 23 October 2025, the European Union (EU) adopted the 19th package of restrictive measures against Russia, and also extended restrictions to Belarus.

The new restrictions concerning Belarus were introduced by a separate EU Council Decision No. 2025/2038, EU Regulation No. 2025/2041, and partially through the Regulation extending sanctions against Russia.

As with previous sanctions packages, the new EU measures include an expansion of individual blocking sanctions against Belarusian persons, as well as further sectoral restrictions and new banking prohibitions.
In this material, REVERA’s legal experts provide a more detailed analysis of the newly introduced restrictions.

Blocking Sanctions

Within the framework of the new sanctions package, the EU has included three Belarusian legal entities and two individuals in its blocking sanctions list.

Inclusion of persons (or entities) in the EU’s blocking sanctions entails the freezing of their assets and a total prohibition on doing business within the EU jurisdiction.

The restrictions include a ban on any person in the EU or any EU resident legal or natural person, regardless of their location, from:

• conducting transactions involving any property, wherever located, that is owned, held, or controlled by a designated person or by an entity acting on their behalf;
• providing any financial or related services in relation to designated persons;
• supplying any goods, wherever located, to a designated person or to an entity acting on their behalf.

Banking Sector

From 2 December 2025, EU persons are prohibited from entering into transactions with three Belarusian banks: Alfa-Bank, Sberbank, and VTB Bank.
However, these banks are not included in the classic list of entities subject to blocking sanctions. The restriction consists solely of a ban on conducting transactions with them, as set out in Article 5ac of Regulation (EU) No. 833 (Russian sanctions regulation).

The Regulation nevertheless provides exceptions allowing operations with these banks in the following cases:

• for the purchase, export, supply, sale, transfer, or transport of pharmaceutical, medical, agricultural and food products, including wheat and fertilisers, provided such operations are permitted under the Regulation and necessary to ensure food security in third countries;
• where strictly necessary to ensure access to judicial, administrative, or arbitral proceedings in a Member State, or for the recognition or enforcement of a judgment or arbitral award rendered in a Member State, provided such operations are consistent with the objectives of this Regulation and Regulation (EU) No. 269/2014;
• where necessary for humanitarian purposes — delivery or facilitation of delivery of humanitarian aid (medical supplies, food), transportation of humanitarian workers, provision of related assistance, or for evacuations;
• where necessary for repayment of debt owed to a national of a Member State or to a legal person, organisation, or body established in the EU;
• where involving a legal person, organisation, or body listed in Annex XLIV, for the provision of correspondent banking services;
• where necessary to make a payment by a national of a Member State or by a legal person, organisation, or body established in the EU, under a loan agreement concluded by a Member State.

Provision of Services to the Public Sector

The new restrictions expand existing measures relating to the Belarusian public sector.
In particular, they concern:

• the supply of software used in the banking and financial sectors;
• the provision of services that contribute to enhancing the technological capabilities of Belarus.
• Furthermore, the restrictions extend to engineering, scientific, and technical consultancy services, including:
• geological, geophysical, and other scientific surveys;
• subsurface exploration;
• surface research and mapping.

Special attention should be paid to the requirement to obtain prior authorisation from the competent authority for the provision of any services to the Republic of Belarus, its government, public authorities, corporations, or agencies.
This applies even to services not yet covered by existing restrictive measures under Regulation (EU) No. 765/2006.

Provision of Artificial Intelligence Services

From 25 November 2025, it is prohibited to directly or indirectly provide commercial space services, including Earth observation and satellite navigation, as well as AI-related services that involve providing access to models or platforms for their training, fine-tuning, or inference, to the Belarusian public sector.

As an exception to these prohibitions — including restrictions related to software and AI services — competent authorities may grant authorisation to provide such software and services only if strictly necessary for the participation of Belarusian citizens in international open-source projects.

Restrictions in the Crypto Sector

The EU had previously introduced restrictions on the provision of wallet creation and maintenance services, other account services, or cryptocurrency custody services.

The prohibitions now extend to the following types of activity:

• crypto-asset services, as defined in Regulation (EU) 2023/1114;
• issuance of payment instruments, acquiring of payment transactions, or payment initiation services, as defined in Directive (EU) 2015/2366;
• issuance of electronic money, as defined in Directive 2009/110/EC of the European Parliament and of the Council.

At the same time, restrictions on the provision of payment services do not impose obligations on payment initiation service providers to verify the citizenship, residence, or registration of each user for every transaction, nor on acquirers to perform sanctions screening of every individual card transaction.

The primary responsibility for sanctions compliance in the execution of payment operations lies with the bank or the provider servicing the client’s account.

Note on the Legal Status in Belarus

In accordance with the legislation of the Republic of Belarus, restrictive measures (sanctions) imposed by third countries have no legal force within the territory of Belarus.
Nevertheless, this information may be useful in assessing arguments by foreign partners regarding the existence or absence of restrictions on their side.

Is Your Business at Risk? Ensure Compliance Now

The new restrictions create legal uncertainty for all entities working with partners from the EU and Belarus.
Non-compliance may result in blocked transactions, asset freezes, and significant fines.

REVERA’s legal team will promptly:

• conduct sanctions due diligence on your counterparties;
• analyse risks associated with sanctioned banks;
• develop contractual and supply chain adjustments.

Author: Alexey Fedorovich

Do not wait until 2 December — ensure your business support in advance.

Contact our lawyers for consultation.