EU Sanctions Against Belarus — 7th Package: Expanded Dual-Use Controls (June 2022)

On 3 June 2022, the European Union adopted its seventh package of sanctions against Belarus, focused primarily on closing circumvention channels and expanding controls on dual-use goods that could support both the Belarusian security apparatus and Russia's war effort in Ukraine.

Context: Circumvention Concerns

By mid-2022, it was apparent that goods subject to EU sanctions were reaching Belarus — and through Belarus, Russia — via third countries and indirect trade routes. The seventh package sought to close these gaps through enhanced due diligence requirements and expanded entity listings.

Individual and Entity Listings

The seventh package added 12 individuals and 8 legal entities to the EU sanctions list, focusing on:

• Officials involved in ongoing repression of political prisoners and civil society
• Companies identified as involved in sanctions circumvention
• Entities facilitating the transfer of military-relevant goods to Russia via Belarus

One additional Belarusian bank was removed from the SWIFT international financial messaging system.

Expanded Dual-Use Entity List

A key element of the seventh package was the expansion of the "entity list" — the list of Belarusian companies subject to enhanced export controls for dual-use goods (items with both civilian and military applications). 24 additional entities were added to this list, meaning any EU export to these companies of dual-use items requires explicit authorisation, which will in practice be systematically denied.

Enhanced Due Diligence Obligations

EU exporters and financial institutions were given enhanced obligations to conduct due diligence on transactions involving Belarus, specifically to identify and prevent indirect transfers of sanctioned goods through third countries. "No re-export to Russia" clauses were encouraged in export contracts.

Additional Sectoral Restrictions

The seventh package extended export controls to additional categories of advanced technology products identified as being used in Russian and Belarusian military systems, based on items recovered from the battlefield in Ukraine.