Canada expanded sanctions against the financial sector of Belarus

On April 11, 2023 the Government of Canada expanded sanctions against Belarus and include nine banks in the designated list:

• Priorbank JSC
• Bank BelVEB OJSC
• BPS Sberbank OJSC
• VTB Bank (Belarus) JSC
• Belorussian-Russian Belgazprombank Joint Stock Company
• Statusbank JSC
• Belarusbank JSC
• National Bank of the Republic of Belarus
• Belagroprombank, JSC

Inclusion of the above mentioned entities in Canada’s blocking sanctions means their asset freeze and a complete ban on doing business in that jurisdiction. Thus, the restrictions prohibit any person in Canada or any Canadian outside Canada from:

• dealing in property, wherever situated, that is owned, held or controlled by listed persons or a person acting on behalf of a designated person;
• entering into or facilitating any transaction related to a prohibited dealing;
• providing any financial or related services in respect of a prohibited dealing;
• making available any goods, wherever situated, to a listed person or a person acting on behalf of a designated person; 
• providing any financial or other related services to or for the benefit of a designated person.
   

Thus, taking into account the fact that in 2022 Canada already included 5 Belarusian banks (Development Bank of the Republic of Belarus OJSC, Alfa-Bank (Belarus), MTBank CJSC, Paritetbank OJSC and BNB-Bank OJSC) into the blocking list, therefore at this time 14 Belarusian banks, including the National Bank of the Republic of Belarus are under the blocking sanctions of Canada.

The expansion of Canadian sanctions on the financial sector of Belarus requires a careful analysis of the sanctions risks associated with the movement of funds and the currency of payment used with counterparties from Canada. It should be noted that foreign banks are characterized by overcompliance, due to which companies may be denied a transaction, even if the Belarusian bank involved in the transaction is not itself included in the blocking sanctions. 

In accordance with the legislation of the Republic of Belarus, restrictive measures (sanctions) of third countries have no legal force in the territory of Belarus. The information may be useful when assessing arguments of foreign partners on the presence/absence of restrictions on their side.

If you have any questions, REVERA Belarus lawyers will be able to advise you.

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