The Belarus sanctions program is administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and is built on a series of executive orders, principally Executive Order 13405 (signed by President George W. Bush in June 2006), which authorized blocking the property of persons undermining democratic processes or institutions in Belarus. The program was significantly expanded after the disputed August 2020 presidential election that returned Alyaksandr Lukashenka to power, the forced diversion of Ryanair Flight 4978 in May 2021, and Belarus's role as a co-belligerent in Russia's 2022 invasion of Ukraine.
Designated persons are placed on OFAC's Specially Designated Nationals and Blocked Persons (SDN) List. U.S. persons are generally prohibited from dealing with them, and any property within U.S. jurisdiction is blocked. Designations have included senior Belarusian government officials, security services personnel implicated in the post-2020 crackdown, state-owned enterprises in the potash, petrochemical, tobacco, and defense sectors, and entities supporting the Belarusian military or facilitating sanctions evasion.
Following the February 2022 invasion of Ukraine, the United States, in coordination with the EU, UK, and Canada, expanded measures against Belarus to mirror many Russia-related restrictions, including export controls administered by the Commerce Department's Bureau of Industry and Security. OFAC has issued general licenses authorizing certain wind-down, humanitarian, and diplomatic transactions, and publishes guidance through its FAQs.
The program is distinct from EU restrictive measures on Belarus (adopted under Council Decision 2012/642/CFSP and subsequent acts) and UK sanctions under the Republic of Belarus (Sanctions) Regulations 2019, though Western jurisdictions often coordinate listings. Enforcement actions against violators can result in substantial civil penalties under the International Emergency Economic Powers Act (IEEPA).
Researchers should consult the current SDN List and OFAC's Belarus Sanctions Resource Center for authoritative designation details, as the scope of the program evolves with new executive orders and general licenses.
Example
In December 2021, OFAC designated 20 Belarusian individuals and entities, including the Belarusian Olympic Committee leadership and state-owned OJSC Belaruskali, citing the Lukashenka regime's human rights abuses and migrant instrumentalization at the EU border.
Frequently asked questions
Executive Order 13405 (2006), issued under IEEPA and the National Emergencies Act, is the foundational authority, supplemented by later executive orders responding to the 2020 election crackdown and Belarus's support for Russia's war in Ukraine.
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