Look up exceptions to the Belarus trade and transport sanctions
As part of statutory guidance to the Belarus regulations: a list of exceptions that allow activities otherwise subject to sanctions in certain defined circumstances.
An exception applies automatically and a licence is not required, but some exceptions have reporting obligations.
To check the full legal wording of an exception, go to the regulation listed in Part 6 of the regulations. If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.
This guide is part of Republic of Belarus sanctions: statutory guidance.
Trade sanctions exceptions
Exceptions for the purchasing in Belarus of mineral products for personal or humanitarian use (regulation 31C)
These exceptions relate to the prohibitions in regulations 27I to 27M relating about the import, acquisition, supply and delivery, and related services, of goods connected to, originating in or consigned from Belarus.
The exceptions apply to a purchase in Belarus of mineral products if the purchase is:
- by an individual on a retail basis for their personal use, or
- solely for the performance of any humanitarian assistance activity in Belarus
Exceptions for personal effects, personal use and diplomatic missions (regulation 31D (1) and (2))
These exceptions relate to prohibitions in regulations 21 to 27 (but not 24A) about the export, supply, delivery, making available, transfer of certain goods and technology, and related services, to or for use in Belarus, to a person connected with Belarus or from a third country to a place in Belarus.
The exceptions apply in relation to critical-industry goods and technology, machinery-related goods and technology and quantum computing and advanced materials goods and technology if they are:
- the personal effects of a person travelling to Belarus
- of a non-commercial nature for the personal use of a person travelling to Belarus and contained in that person’s luggage, or
- necessary for the official purposes of a diplomatic mission, consular post or international organisation enjoying immunities
Exceptions for luxury goods and gold jewellery being moved to Belarus (regulation 31D, (3) and (3A))
These exceptions relate to prohibitions in regulations 21 to 23 about the export, supply, delivery and making available of certain goods and technology to or for use in Belarus, to a person connected with Belarus or from a third country to a place in Belarus.
Exceptions apply to luxury goods that are:
- necessary for the official purposes of a diplomatic mission or consular post in Belarus, or of an international organisation enjoying immunities in accordance with international law, or
- the personal effects of their staff
Another exception applies to gold jewellery exported by a person travelling to Belarus if it is:
- non-commercial jewellery that is for personal use of and owned by the natural person importing it, or an immediate family member, travelling to Belarus, contained in their luggage provided that the jewellery is not intended for sale
Exceptions for gold jewellery, gold and processed gold being moved from Belarus (regulation 31D (3B) and (3C))
These exceptions relate to prohibitions in regulations 27I to 27M about the import, acquisition, supply and delivery, and related services, of goods consigned from or originating in Belarus, including from a third country.
One exception applies to any gold, gold jewellery and processed gold if it is:
- necessary for the official purposes of a diplomatic mission or consular post in Belarus, or an international organisation enjoying immunities in accordance with international law
A second exception applies to the import or acquisition of gold jewellery by a person who is travelling to the United Kingdom if it is:
- non-commercial jewellery that is for personal use of and owned by the natural person importing it, or an immediate family member, travelling to Belarus, contained in their luggage, provided that the jewellery is not intended for sale
Exceptions for consumer communication devices for civilian use (regulation 31E)
These exceptions relate to prohibitions in regulations 21 to 27 (but not 24A) about the export, supply, delivery, making available, transfer of certain goods and technology, and related services, to or for use in Belarus, to a person connected with Belarus or from a third country to a place in Belarus.
The exceptions apply in relation to critical-industry goods and technology, machinery-related goods and technology and luxury goods if they are:
- consumer communication devices for civilian use, or
- software updates for civilian use
Exception for emergencies in certain cases (regulation 31F)
This exception relates to the prohibitions in regulations 21 to 27 (but not 24A) about the export, supply, deliver, making available and transfer of critical industry goods and technology, machinery-related goods and technology and oil-refining goods and technology, and related services, to or for use in Belarus, to a person connected with Belarus, or to a place in Belarus.
The exception applies if:
- the act is assisting with the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, infrastructure or the environment
There is a notification requirement that justification is received within 5 working days of the day on which the act was done.
Exception for technical assistance to aircraft and ships in an emergency (regulation 31G)
This exception relates to the prohibitions in regulation 27N about technical assistance to or for the benefit of a designated person in relation to an aircraft or ship.
The exception applies if:
- failure to provide that assistance would endanger the lives of persons on board the aircraft or ship or the safety of the aircraft in flight, or the ship at sea
Exceptions for banknotes (regulation 31J)
These exceptions relate to the prohibitions in regulations 21 to 23 about the export, supply, delivery and making available of goods and technology.
The exceptions apply to banknotes necessary for the personal use of natural persons and their immediate family travelling to Belarus if:
- the banknotes are up to the value of £10,000, or
- it is necessary for the official purposes of diplomatic missions, consular posts or international organisations in Belarus enjoying immunities in accordance with international law (any amount)
An exception also applies if the person carrying out the activity did not know and had no reasonable cause to suspect that the banknotes were for a person connected with Belarus or for use in Belarus.
Exceptions for machinery-related goods and technology (regulation 31K)
These exceptions relate to the prohibitions in regulations 21 to 27 about the export, supply, delivery, making available and transfer, and related services, of goods and technology.
The exception applies in relation to machinery-related goods and technology for a non-military use and for a non-military end user, if it is necessary for:
- humanitarian assistance activity
- addressing health emergencies
- providing a response to natural disasters
- medical or pharmaceutical purposes
- the benefit of the civilian population of a country
- temporary use by news media, or
- ensuring cyber-security and information security for persons in Belarus except for its government and undertakings directly or indirectly controlled by that government
Transport sanctions exceptions
Exceptions for certain aircraft to make UK landings and use UK airspace (regulation 31H)
These exceptions relate to prohibitions in regulation 29A about the overflight and landing in the UK of certain aircraft.
The exceptions apply to a landing, or overflight preparatory to a landing, if:
- failing to land would endanger the lives of persons on board or the safety of the aircraft, or
- required in accordance with a movement direction under regulation 29A
Exception for certain ships to enter UK ports (regulation 31I)
This exception relates to prohibitions in regulation 29F about the granting of, or causing or permitting, access to a UK port.
The exception applies if:
- the access is needed by a ship in the case of an emergency, or
- required in accordance with a movement direction under regulation 29H