16 Jun 2006 Sanctions United States
Sanctions

US Sanctions Against Belarus — OFAC Regime (2006–present)

Belarus Virtual Consult

The United States maintains a comprehensive sanctions programme against Belarus administered by the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury, in close coordination with the State Department and the Commerce Department's Bureau of Industry and Security (BIS). The US Belarus sanctions regime is one of the most extensive maintained by any single country and has expanded significantly since its establishment in 2006.

Executive Order 13405 — June 2006

The legal foundation of US Belarus sanctions is Executive Order 13405, signed by President George W. Bush on 16 June 2006. The order declared a national emergency with respect to Belarus, citing:
  • The actions of the Lukashenko government in undermining democratic processes and institutions in Belarus
  • Electoral fraud in the March 2006 presidential election
  • Public corruption and repression of civil society
E.O. 13405 authorised OFAC to designate and block the property of persons responsible for these actions or providing material support to the Lukashenko government. The Belarus Sanctions Regulations (31 CFR Part 548) formally codified the programme in 2010.

Initial Designations (2006–2011)

OFAC made initial designations of Belarusian officials under E.O. 13405 following the 2006 and 2010 elections. In 2008, two state-owned companies — Lakokraska OAO and Polotsk Steklovolokno OAO — were designated. Four additional entities were designated in August 2011. A general licence authorised transactions with certain previously designated entities during wind-down periods.

April 2021 — Revocation of General Licence

In April 2021, OFAC revoked a key general licence that had previously authorised US persons to engage in transactions with certain Belarusian state-owned entities. This reactivated full sanctions on those entities, prohibiting US persons from conducting any dealings with them.

Executive Order 14038 — August 2021

On 9 August 2021, President Joe Biden issued Executive Order 14038, dramatically expanding the US Belarus sanctions framework. The new order authorised OFAC to designate:
  • Belarusian government officials and their family members
  • Senior executives of blocked entities
  • Persons operating in key economic sectors: defence, security, energy, potash, tobacco, construction and transportation
  • Persons engaged in election fraud, human rights violations or public corruption
Initial designations under E.O. 14038 included Belaruskali OAO, the world's largest potash producer, as well as multiple energy and financial sector companies. A 45-day wind-down period (General Licence 4) was provided for Belaruskali transactions through 8 December 2021.

December 2021 — Coordinated Package

On 2 December 2021, coordinating with the EU, UK and Canada, OFAC designated 20 individuals, 12 entities and 3 aircraft on the Specially Designated Nationals (SDN) List, targeting the defence, security, tourism and potash sectors. The Treasury also issued Directive 1 under E.O. 14038, prohibiting US persons from dealings in new debt issued by Belarus's Ministry of Finance or Development Bank with a maturity exceeding 90 days.

August 2024 — Fourth Anniversary

On 9 August 2024, the US joined coordinated action with the EU, UK and Canada, imposing additional designations on Belarusian officials and entities, including those involved in the facilitation of Russia's war in Ukraine via Belarusian territory and infrastructure.

Commerce Department — BIS Controls

In parallel with OFAC measures, the US Bureau of Industry and Security (BIS) has imposed extensive export controls on Belarus, including:
  • Military end-use and end-user controls
  • Entity list designations for Belarusian companies
  • Expanded controls on semiconductor exports and other dual-use technologies

Scope and Extraterritorial Reach

US Belarus sanctions apply to all US persons (citizens, permanent residents, US-incorporated entities and their foreign branches) and to all transactions conducted in US dollars that clear through the US financial system. Secondary sanctions risk exists for non-US entities that provide material support to sanctioned Belarusian parties.