EU Sanctions against Belarus 2026: What Companies Must Review

Key data

Companies with any type of link to Belarus have a new and urgent obligation as of 23 April 2026. The Council Regulation (EU) 2026/513 updates the European sanctions framework against that country, amending Council Regulation (EC) No 765/2006, which is the base regulation governing restrictive measures against Belarus for many years.

It is not a regulation for future application: it entered into force on the same day of its publication. Any ongoing operation that does not comply with the new measures may result in immediate legal liability.

What does this regulation establish?

Regulation (EU) 2026/513 amends Regulation (EC) 765/2006, which is the EU's central legal instrument for imposing restrictive measures on Belarus in the context of its participation in the Russian aggression against Ukraine.

The restrictive measures contemplated by this updated sanctions framework include:

• Adjustments to lists of designated persons and entities: natural and legal persons subject to restrictions may be added or modified.
• Asset freezing: the assets of designated persons and entities are blocked and cannot be made available to them.
• Transaction prohibitions: certain commercial, financial or investment operations with the affected entities or persons are prohibited.

European companies have the obligation to verify that none of their counterparties in Belarus appear on the updated lists and that none of their operations violate the current prohibitions.

This update occurs in the context of Belarus's support for the Russian invasion of Ukraine, which has led the EU to progressively strengthen the sanctions framework since 2022.

Economic and operational impact

The impact for companies is not only legal: it is operational and financial. The most exposed areas are:

• Supply chain: any supplier, intermediary or logistics partner based in or linked to Belarus must be verified against the updated lists.
• Existing contracts: contracts in force with Belarusian counterparties may be suspended or unenforceable if the counterparty is designated or if the operation is prohibited.
• Financial operations: payments, collections, financing or guarantees related to Belarus require immediate review by finance and compliance departments.
• Investments: any investment position in Belarusian entities or with significant exposure to the country must be evaluated.

The cost of non-compliance can be much higher than the cost of adaptation: the Regulation establishes that non-compliance may result in serious administrative and criminal sanctions. Compliance and legal departments must update their due diligence procedures without delay.

Who does it affect?

• Import or export companies with commercial operations with Belarus or using transit routes that pass through that country.
• Financial entities and banks that manage payments, financing, letters of credit or guarantees linked to Belarusian counterparties.
• Investors and funds with positions in Belarusian companies or with indirect exposure to the country.
• Logistics and transport companies operating routes with origin, destination or transit in Belarus.
• Compliance and legal departments of any company in the above categories, responsible for updating due diligence procedures.
• Advisors, consultants and lawyers providing services to companies with links to Belarus.
• Natural persons maintaining investment or financial relationships with entities or persons in Belarus.

Practical example

A Spanish industrial company that imports components through a distributor based in Minsk must act immediately on three fronts:

1. Verify whether that distributor appears on the updated lists of designated entities by Regulation (EU) 2026/513. If it does, any pending payment or ongoing delivery is blocked.
2. Review the supply contract to identify whether any clause involves transfer of funds or assets to Belarusian entities that may be subject to freezing.
3. Document the verification and due diligence process carried out, as in case of inspection or investigation, the company must prove that it acted with due diligence from the entry into force of the regulation on 23 April 2026.

If the company does not carry out this review and continues to operate with a designated entity, it exposes itself to serious administrative and criminal sanctions, regardless of whether the non-compliance was intentional or not.

What should companies do now?

1. Immediately audit Belarusian counterparties: identify all suppliers, customers, partners and intermediaries with links to Belarus and verify them against the updated lists of designated entities and persons.
2. Review existing contracts: analyze whether any active contract involves operations that may be prohibited under the new sanctions framework or with entities now designated.
3. Block ongoing financial operations if there is risk: preventively suspend payments, collections or transfers linked to Belarus until compliance verification is completed.
4. Update due diligence procedures: compliance and legal departments must incorporate the new obligations of Regulation (EU) 2026/513 into their internal counterparty review protocols.
5. Train the teams involved: procurement, finance, legal and operations must understand the new restrictions and know how to act when facing a potentially designated counterparty.
6. Document all actions taken: in case of inspection, the company must be able to prove that it acted with due diligence from 23 April 2026, the date of entry into force.