EU Sanctions Against Belarus — 9th Package: Broadest Economic Measures to Date (June 2024)

On 29 June 2024, the European Union adopted its ninth package of sanctions against Belarus — the most comprehensive set of economic measures imposed to date, targeting trade, services, transport and anti-circumvention mechanisms. The package was adopted in direct response to Belarus's sustained role in facilitating Russia's war of aggression against Ukraine.

New Import Bans

The ninth package introduced import bans on Belarusian goods in sectors not previously covered:

• Gold and gold products
• Diamonds
• Helium — Belarus is a transit country for Russian helium exports
• Coal
• Crude oil and certain petroleum products (expanded beyond previous restrictions)

New Export Restrictions

Expanded controls on exports from the EU to Belarus in:

• Industrial machinery and equipment used in oil refining
• Maritime equipment and navigation technology
• Luxury goods (expanded categories)
• Additional dual-use goods and technologies

Transport Measures

A significant new element of the ninth package was the transport ban:

• Belarusian-registered road transport vehicles are banned from EU territory
• Enhanced controls on rail freight transiting through Belarus

The "No-Belarus Clause"

One of the most innovative elements of the ninth package was the introduction of a contractual obligation — the "no-Belarus clause." EU exporters in specific sectors are required to include in their contracts a clause prohibiting the re-export of goods to Belarus or for use in Belarus. This places legal due diligence responsibility directly on EU companies and creates liability for knowingly enabling circumvention.

Professional Services

The ninth package also expanded prohibitions on providing professional services to Belarusian state entities:

• Accounting, auditing and bookkeeping services
• Legal advisory services
• IT consulting and software services
• Management consulting and public relations services
• Advertising services

Investment Restrictions

New restrictions prohibited EU investment in and joint ventures with Belarusian state-controlled companies in the energy sector and other strategic sectors.

Scale of EU Sanctions by June 2024

By the ninth package, EU restrictive measures against Belarus encompassed:

• Over 250 designated individuals subject to travel bans and asset freezes
• Over 40 designated entities
• Sectoral trade restrictions covering potash, petroleum, tobacco, coal, gold, diamonds, helium
• Financial sector restrictions including SWIFT bans on major banks
• Aviation ban
• Transport bans on road freight vehicles
• Extensive export controls on dual-use goods, technology and industrial equipment
• Professional services bans