Republic of Belarus sanctions: guidance

The UK government has published a revised version of its „Belarus sanctions guidance“ whose key purpose it is to support firms in their efforts to comply with the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (SI 2019/600). It thereby covers issues such as
(1) the purpose and scope of the regulation;
(2) the prohibitions made by the regulation and the implications for UK firms (what do they have to look out for, which actions are disallowed);
(3) licenses under the regulation and how to obtain such license (a license must be applied for, if permission is sought to conduct an activity that would otherwise be prohibited by the regulation); and
(4) recordkeeping and reporting requirements of UK firms regarding their compliance with the regulation.
According to the update history, new licensing grounds have been added. In fact, our text comparison tool revealed that a license may now be granted for „the provision of technical assistance, brokering services, financial services or funds related to machinery-related goods or technology, if the technical assistance,
brokering services, financial services or funds relates to the execution of contracts concluded before 9 June 2023 or ancillary contracts necessary for the execution of such contracts, provided the actions carried out under these contracts are completed by 17 July 2023 or as soon as possible thereafter“.
A corresponding provision that allows the application for a license for purposes of exporting, making available of, transferring, supplying, or delivering, „non-lethal military goods or technology, if the goods relate to the execution of contracts concluded before 9 June 2023 or ancillary contracts“ was also published. Both provisions may be found on page 27 and 28.