The EU's 21st Sanctions Package Against Russia

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Consequences for the Lukashenko Regime

European Commission President Ursula von der Leyen, who presented the initial draft of the 21st sanctions package on June 9, mentioned a proposal to align trade restrictions on Belarus with the measures against Russia in order to prevent sanctions evasion.

"We are coordinating trade restrictions on Belarus so that it cannot serve as a loophole for Russian trade," Ursula von der Leyen stated. In the end, that is exactly what happened. The list of products banned from export to Belarus was expanded. Restrictions now cover nickel and beryllium powders, nickel and its alloys, certain materials for the aviation and defense industries, as well as drone equipment, including ground control stations, electronic jamming and interception systems, launchers, servomotors, and flight interruption systems.

The EU also introduced additional restrictions on imports of goods from Belarus. These cover a number of ores and metals, unwrought zinc, zinc and chromium oxides, tall oil, glassware, and automotive parts. Transitional periods are provided for contracts already concluded: deliveries of tall oil, glassware, and auto parts are allowed to be completed until October 25, 2026, and Hungary will be able to continue importing certain Belarusian hydrocarbons until the end of the year.

Other details of the proposed sanctions against Belarus for supporting Russian aggression against Ukraine include:

• oil refineries in Russia and Belarus, with EU sanctions specifically targeting the European Trading Company LLC (a distributor of Belarusian petroleum products in Russia) and the Mozyr Oil Refinery;

• a ban on cryptocurrency operations for 11 cryptocurrency platforms and companies (including a Belarusian crypto platform and Hi-Tech Park resident White Bird) that help Russia evade sanctions;

• the addition of new Belarusian companies to the sanctions list for assisting Russia's military industry (Chip and Dip LLC; Rogachev "Diaproyektor" Plant OJSC; KB Displei OJSC; Zavod Korpusnykh Izdeliy CJSC);

• expansion of the ban on Belarusian citizens owning assets in, controlling, or sitting on the board of directors of any company providing services in the cryptocurrency market and regulated by MiCA — the EU's Markets in Crypto-Assets regulation;

• protection of legal entities from lawsuits outside the European Union in connection with compliance with sanctions requirements.

EU member states also agreed to extend the current price cap on Russian oil for another 12 months. The new sanctions package expands restrictions on the Russian financial sector (32 Russian banks), bans specific transactions, and introduces new rules on the use of cryptocurrency, while also adding more vessels of Russia's shadow fleet and their intermediaries to the sanctions list.

The new package will also restrict visas for former Russian military personnel, introduce additional trade bans, and place sanctions on approximately 218 new organizations. At the same time, due to the positions of several member states, restrictions on fish trade were dropped, measures against Russian military personnel were softened, and Patriarch Kirill was removed from the list.

A compromise was also reached on supplies of Russian LNG to third countries. Greece successfully insisted that the EU allow deliveries and related purchases under contracts signed before February 24, 2022, although any increase in volumes by EU operators will be limited, and the EU Council will review the exemption annually.

This is an important sanctions package for Belarus. Despite the fact that the regime has thrown colossal effort into preventing new sanctions from being introduced, freezing them, or even having them lifted and weakened, the pressure continues and is intensifying. Most importantly, the attitude toward the Lukashenko regime has not changed.

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