EU Sanctions Against Belarus — Banking Sector Measures (February 2022)

On 17-18 February 2022, the European Union adopted targeted measures against two Belarusian financial institutions, specifically designed to restrict access to EU capital markets and limit the capacity of the Belarusian banking system to finance state activities.

Institutions Targeted

The February 2022 measures added two Belarusian banks to the EU sanctions framework:

• Development Bank of the Republic of Belarus — the state development bank responsible for financing major infrastructure and strategic investment projects
• Bank Dabrabyt (JSC) — a commercial bank with state links

Measures Applied

The restrictions on these institutions included:

• Prohibition on providing investment services and access to EU securities and credit markets
• Prohibition on accepting deposits from these institutions
• Restrictions on correspondent banking relationships
• EU persons prohibited from purchasing securities issued by these entities

Context: Pressure on State Financing

The targeting of development finance institutions reflected a strategic evolution in EU sanctions: by restricting the Belarusian state's ability to raise funds through EU financial channels, the measures sought to increase the long-term financial costs of the Lukashenko government's political choices. These banking measures were adopted in parallel with intensifying EU discussions about the Russia-Belarus Union State and growing concerns about Belarus's role in facilitating Russia's military buildup ahead of the invasion of Ukraine, which occurred six days later, on 24 February 2022.

Subsequent Developments

The invasion of Ukraine by Russia — supported logistically by Belarus, which allowed Russian forces to use Belarusian territory to attack Kyiv — triggered a dramatic acceleration of EU sanctions activity. The measures of February 2022 were therefore followed within weeks by a far more sweeping sixth sanctions package.