On the 21st May 2021, the UK imposed additional sanctions on Belarus. This was in response to human rights abuses, activities relating to the August 2020 presidential election, and the forced diversion of Ryanair Flight 4978 to Minsk. The result of this diversion was the arrest of Roman Protasevich and his partner Sofia Sapega.
The UK Sanctions regime is aimed to encourage the Government of Belarus to:
- respect democratic principles and the rule of law in Belarus;
- refrain from repressing civil society in Belarus;
- properly investigate the disappearance of opposition political opponents and journalists who were critical of the current Government of Belarus;
- comply with international human rights law, and
- respect human rights.
The UK Government is currently developing plans in collaboration with the EU, US and Canada for additional measures
targeting specific sectors of the Belarusian economy, which may include Belarus’s financial sector. A further announcement
is expected to be made.
Conclusion
Depending on your firm’s risk appetite, it would be a prudent step to assess Belarus against your firm’s Country Risk Rating. The upgraded restrictive measures from ‘Targeted’ to ‘Sectorial,’ may influence Belarus’s country risk rating, along with any customers or business operations your firm may have in that jurisdiction.
Trade Finance is vulnerable to indirect exposure to these new sectoral restrictions on Belarusian Oil Refineries. It is advisable to conduct Enhanced Due Diligence on all documentation related to Letters of Credit that may finance crude oil trades.
It is important to establish that the crude oil subject to the trade is not of Belarusian origin, and not refined by one of the nine sanctioned Belarusian Oil Refineries. Firms facilitating such trade may breach these measures.