22nd November 2021

EU Broadens Belarus Sanctions Program Over Border Fears

As thousands of migrants gather on the Belarusian borders hoping to cross into Western Europe, the EU has amended the scope of its sanctions program in order to target individuals or entities that are facilitating illegal crossings.

The latest changes to continuing sanctions against Belarus and its President Alexandr Lukashenko, see the EU broaden the listing criteria on which specific designations can be based. 

It follows European Council conclusions in October, in which EU leaders declared that they would not accept any attempt by third parties to instrumentalize migrants for political purposes, condemned all hybrid attacks at the EU’s borders, and affirmed that it would respond accordingly.

Lukashenko is accused of giving migrants tourist visas and helping them enter the EU illegally through Poland, Lithuania, and Latvia, the three EU states it borders, in retaliation for EU sanctions imposed after he won a disputed election in 2020.

Officials in Brussels say such “gangster-style” tactics are inhumane and exploitative. Meanwhile, Russia, Belarus’s main ally, denies the allegations and blames Poland and Lithuania for not handling the crisis properly.

In July and August, Lithuania saw 50 times more asylum seekers than in the whole of 2020 and declared a state of emergency to deal with the crisis – a move repeated by Poland in September, as it faced the same problem. In November, Poland reinforced its border with more than 12,000 soldiers.

Key takeaways 

A total of 166 individuals and 15 entities are now designated under EU sanctions on Belarus. These include Lukashenko and his son and national security adviser, Viktor Lukashenko, as well as other key political and government figures, members of the judicial system, and several prominent economic actors. Measures against designated persons include travel bans and an assets freeze.

The EU deploys sanctions as part of its Common Foreign and Security Policy in order to protect its  security interests, address violations of treaty agreements and international law, or punish human rights abuses.

In May, additional measures were imposed after a flight from Greece to Lithuania was grounded in Belarus’s capital Minsk so that opposition journalist Roman Protasevich and his girlfriend could be arrested.

In June, the EU banned Belarusian carriers from crossing its airspace, accessing its airport, and imposed additional targeted economic sanctions.

Members of the UN Security Council released a joint statement by the US, UK, France, Albania, Estonia, and Ireland in November, accusing Belarus of putting migrants’ lives at risk for political purposes and trying to divert attention “away from its own increasing human rights violations”.

On 11 November, Mr. Lukashenko warned he would respond to any fresh EU sanctions, threatening to cut off supply to the Russian gas pipeline that runs through Belarus and into the EU. “We are heating Europe and they are threatening us,” he said.

“And what if we shut off natural gas there? Therefore, I would recommend the leadership of Poland, Lithuanians and other empty-headed people think before speaking.”

Managing the EU’s border situation has been a long-standing geopolitical challenge, with flashpoints in Greece, Germany and Turkey, which could signal wider use of sanctions as a tool to manage migration challenges in the future.

Compliance teams should ensure they are screening against up-to-date sanctions lists and keep a careful eye on government statements for any regional developments affecting sanctions. They should also maintain awareness of geopolitical angles and make sure that any exposures are understood.


Read more about the latest sanctions changes, hotspots and geopolitical trends in our 2021 report.

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