Belarus sanctions tightened: crypto, AI and due diligence from 1 October

Deposits from Belarusian nationals, persons resident in Belarus and Belarus-established entities stay capped at 100,000 euro per credit institutionLovdata, and providing crypto-asset services as defined in Regulation (EU) 2023/1114, issuing payment instruments, acquiring payment transactions or providing payment initiation services as defined in Directive (EU) 2015/2366, or issuing electronic money to those persons stays prohibitedLovdata. From 26 March 2025, Belarusian nationals and residents may not directly or indirectly own or control, or hold posts in the governing bodies of, entities providing crypto-asset wallet, account or custody servicesLovdata. Nationals and residents of EU and EEA states and Switzerland fall outside the bansLovdata, and personalised security credentials for account access at an established credit institution or e-money institution are exemptLovdata.

Exporters of dual-use items, military-list goods and listed revenue-generating goods face extended bans with staggered run-offLovdata. Selling, supplying, transferring or exporting goods and technology on the EU Common Military List to or from Belarus is banned, together with related brokering, technical assistance and financingLovdata, save for narrow exceptions covering humanitarian and protective use, UN and EU programmes and operations, maintenance and safety of existing EU capacities, and pre-20 July 2025 contracts. Grandfathering cut-offs for pre-existing contracts in chemicals, minerals, machinery and other listed goods shift from the EU reference dates to later Norwegian dates running from 2 October 2026 to 4 July 2027Lovdata. Authorised transit through Belarusian territory stays available for humanitarian, medical, civil-nuclear and maintenance-lease purposesLovdata.

Technology and service providers face new bans. From 25 November 2025, commercial earth-observation and satellite-navigation services, artificial intelligence services giving access to models or to platforms for training, fine-tuning and inference, and high-performance, GPU-accelerated and quantum computing services may not go to the Belarusian state, its public bodies and corporations, or persons acting for them. Any other service outside the listed professional, construction, marketing, software and technology bans needs case-by-case prior authorisationLovdata. New software listed in Annex XXXII is banned for Belarusian persons or use in Belarus, with an exemption where supply secures critical power supply in the EULovdata, while enterprise-management, industrial-design and listed banking and finance software stays restricted with contract run-off into January 2026Lovdata.

Sellers, suppliers, transferors and exporters of common high-priority items in Annex XXX and goods in Annex XXXI must identify and assess the risk of export to or for use in BelarusLovdata, document the assessment and keep it updatedLovdata, maintain proportionate controlsLovdata, and ensure non-EU entities they own or control do the sameLovdata. The duty applies from 12 April 2025 for Annex XXX goodsLovdata and from 31 December 2026 for Annex XXXI goods, and falls away only for operators dealing exclusively inside the EU or listed partner countriesLovdata. Breach reports must flag crypto-asset useLovdata.

Enforcement is sharper. Frozen funds or payments blocked only because a listed correspondent bank handled the transfer can be released where sender and recipient are unlisted and the transfer breaches no asset-freeze ruleLovdata, with one authorisation per applicantLovdata, no application to assets held by central securities depositoriesLovdata, and notice to other states within a weekLovdata. Persons harmed by third-country claims over sanctioned contracts can recover damages before Member State courtsLovdata, and third-country or investor-state rulings invoked by listed persons will not be recognised or enforcedLovdata. Tolletaten, the AML supervisory authorities and Økokrim are named as the competent Norwegian touchpointsLovdata. The amendments enter into force on 1 October 2026Lovdata.

Legal basis: lov 16. april 2021 nr. 18 om gjennomføring av internasjonale sanksjoner (sanksjonsloven) § 2, implemented through forskrift 8. september 2006 nr. 1041 as amended by forskrift 14. september 2026 nr. 1810.