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EU expands economic sanctions against Belarus

25 November 2021

The European Union has responded to the ongoing migrant crisis in Belarus by expanding sanctions against the country to include insurance and re-insurance.

These new sanctions may have an impact on EU companies that have exposure to dealings with Belarus or Belarusian entities, who will need to comply with relevant restrictions. Companies doing business in or with Belarus will need to assess their risk exposure to the new measures and take appropriate due diligence measures to allow them to remain compliant.

The EU has adopted an exemption to the prohibition on the provision of insurance and re-insurance to the Belarusian Government, its public bodies, corporations or agencies where the risk insured is situated in the EU.

Specifically, the prohibition does not apply to the provision of compulsory or third party liability insurance to Belarusian persons, entities or bodies where the risk insured is situated in the EU or to the provision of insurance for Belarusian diplomatic or consular missions in the EU. The prohibition is without prejudice to the execution of contracts concluded before 25 June 2021, or ancillary contracts necessary for the execution of such contracts.

For more than a year, the EU has progressively expanded its restrictive measures on Belarus in light of the alleged fraudulent presidential elections that took place in the country. As a response, the EU adopted in June 2021, the comprehensive restrictions on a significant part of the Belarusian economy including the tobacco, potash, petroleum, banking and insurance sectors.

On 15 November 2021, the EU amended its sanctions regime on Belarus to broaden the listing criteria on which specific designations can be based (Council Regulation (EU) 2021/1985 and Council Decision (CFSP) 2021/1990). Measures against designated persons include travel bans and an assets freeze.

So far, 166 individuals and 15 entities have been affected by EU sanctions.

Estonia, the Baltics and Poland have all called for further sanctions on officials in Minsk to counteract what they see as a "hybrid" attack on the EU's borders after thousands of migrants tried to cross Belarus' borders into Europe.

In a statement Estonia's Minister of Foreign Affairs Eva-Maria Liimets said the broadening of sanctions will allow the EU to act quicker in the future. "Next, we must enforce these sanctions as soon as possible to help initiate a dialogue to end the confrontation," said Liimets.

The Minister also expressed Estonia's continued solidarity with Poland, Latvia and Lithuania adding: "We have consistently used all diplomatic tools to end the hybrid attack and reduce migratory pressure, and we are ready to support Poland, Latvia and Lithuania in any way they need."

If you wish to discuss any insurance questions or have any queries, please visit or contact Vida Jarašiūnaitė

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