EU Sanctions Against Belarus — 5th Package: Migration Instrumentalization (December 2021)

On 2 December 2021, the European Union adopted its fifth package of sanctions against Belarus, with a new and specific focus on the Lukashenko regime's deliberate orchestration of a migration crisis at the EU's eastern border.

The Hybrid Migration Crisis

From the summer of 2021, Belarusian state and security services began systematically facilitating the travel of migrants — primarily from Iraq, Syria and Afghanistan — to Belarus, and then directing them towards the borders of Poland, Lithuania and Latvia, all EU member states. Evidence gathered by EU intelligence services, investigative journalists and border agencies showed that:

• Belarusian state travel companies and airlines advertised and sold travel packages to migrants, including visa-on-arrival arrangements
• Belarusian border guards and military personnel physically directed migrants to crossing points and, in some cases, pushed them across the border using force
• Migrants reported being threatened and coerced by Belarusian authorities into attempting illegal crossings
• Belavia, the Belarusian state airline, continued operating flights from Middle Eastern cities despite calls to stop

The EU formally characterised this as a "hybrid attack" — the deliberate use of vulnerable human beings as a geopolitical weapon against EU member states.

Individuals and Entities Listed

The fifth package added 17 individuals and 11 entities to the EU sanctions list, specifically targeting those involved in the instrumentalization of migrants:

• Officials of the Belarusian border service and migration authorities
• Travel agencies that had organised migration facilitation packages
• Belavia Airlines — the Belarusian national carrier — listed for its role in transporting migrants
• Hotels and tourist operators that had participated in facilitating migrant accommodation as part of transit arrangements

Total cumulative designations reached 183 individuals and 26 entities.

Expanded Listing Criteria

The fifth package also formally expanded the legal criteria for listing to include individuals and entities that "organise or contribute to activities by the Lukashenko regime that facilitate the illegal crossing of the EU's external borders." This created the legal basis for future designations in this category.

Food Import Measures

Additionally, import restrictions were extended to certain Belarusian food products, expanding the economic pressure beyond the industrial and energy sectors targeted in the fourth package.