Trade Alert

Sanctions Against Belarus

By In USA Trade Alerts On 3rd March 2022


In a pre-publication Federal Register notice scheduled to be published March 8, 2022,  the Bureau of Industry and Security (BIS) details the specifics on sanctions against Belarus under the Export Administration Regulations (EAR).  The sanctions mimic those imposed on Russia. 

Summary from the Federal Notice:

  • New Commerce Control List (CCL)-based license requirements for Belarus;
  • Revise the two foreign “direct product” rules (FDP rules) that are specific to Russia and Russian ‘military end users’ to make them also applicable to Belarus and Belarusian ‘military end users;’ specify a license review policy of denial applicable to all of the license requirements on Belarus that are being added in this rule, with certain limited exceptions;
  • Significantly restrict the use of EAR license exceptions; expand the existing ‘military end use’ and ‘military end user’ control scope to include Belarus for all items “subject to the EAR” other than food and medicine designated EAR99;
  • Add two new Belarusian entities to the Entity List as ‘military end users.’
  • This rule also imposes a license requirement for nuclear nonproliferation items for exports and reexports to Belarus and removes Belarus from Country Group A:4 under the EAR. In addition, for Belarus and Russia, this rule amends the availability of License Exceptions AVS and ENC and includes clarifying guidance on the availability of CCD.

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