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Sanctions: The Republic of Belarus

Wednesday, 6 July 2022

The Treasury advises that the Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 (of UK Parliament) (the “Republic of Belarus Regulations”) [SI 2022/748] came into operation on 5 July 2022 and amends the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/600) (“the 2019 Regulations”). The 2019 Regulations, as amended, are extended to the Island by the Republic of Belarus (Sanctions) (EU Exit) (Isle of Man) Order 2021 [SI 2021/1257].

The Republic of Belarus Regulations were amended in the United Kingdom in response to the Government of Belarus supporting Russia’s actions in respect of Ukraine.  The Isle of Man has adopted these measures to ensure that sanctions against the Republic of Belarus in the Island are aligned with the United Kingdom.

These Regulations provide for a number of new restrictions imposed in relation to trade with the Republic of Belarus (i.e. imports, exports and related services) in —

  • financial services for the purpose of foreign exchange reserve and asset management
  • critical industry
  • quantum computing
  • oil refining
  • luxury goods
  • mineral products
  • arms and related material
  • iron and steel
  • technical assistance and financial services
  • enabling or facilitating military activities
  • technical assistance provided in relation to ships.

Existing restrictions on dealing with financial instruments and providing loans are extended to a broader range of transferable securities, money market instruments, loans and credit.

Existing prohibitions relating to dual-use goods and technology are also extended to include a wider range of products and services.

The current aircraft restrictions are widened so that it will now be an offence for certain Belarus-related aircraft to land in, or overfly, the Isle of Man, and for such aircraft to be registered in the Isle of Man.  The Regulations also adds shipping restrictions, prohibiting certain Belarus-related or other specified ships from entering Isle of Man ports or being registered in the Isle of Man, and providing powers to the Secretary of State to direct the movement and detention of such ships.

New exceptions in respect of the new trade provisions are included for travellers, diplomatic posts, international organisations, consumer communication devices and software, and for emergencies.

Additionally the Regulations make related changes to information and enforcement powers, to Schedules, and to other legislation.

Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.

Further details of the sanctions regime related to the Republic of Belarus and links to other financial sanctions regimes may be found on the Customs and Excise pages of the Isle of Man Government website.

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